Attachment 2 - 2024 Amended Eastern San Joaquin Groundwater Sustainability Plan — Manteca City Council, April 15, 2025 (part 3 of 6)

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(b) The organization and management structure of the Agency, identifying persons with management authority for implementation of the Plan. 1-2:1-6

1.1.3:1.1.4. 3 1-2:1-3
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(c) The name and contact information, including the phone number, mailing address and electronic mail address, of the plan manager. 1-2 1.1.3 1-2
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(d)
The legal authority of the Agency, with specific reference to citations setting forth the duties, powers, and responsibilities of the Agency, demonstrating that the Agency has the legal authority to implement the Plan. 1-10, X-X:XX 1.1.4.4, Appendix 1- B This field was updated to reflect changes made in the Revised GSP, updated June 2022. Pages __ reference Appendix 1-B. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024. (e) An estimate of the cost of implementing the Plan and a general description of how the Agency plans to meet those costs. 1-10, 7-6:7- 8 1.1.4.5, 7.2 7-2
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Note: Authority cited: Section 10733.2, Water Code. Reference: Sections 10723.8, 10727.2, and 10733.2, Water Code. § 354.8. Description of Plan Area
Each Plan shall include a description of the geographic areas covered, including the following information:
(a) One or more maps of the basin that depict the following, as applicable:
(1)
The area covered by the Plan, delineating areas managed by the Agency as an exclusive Agency and any areas for which the Agency is not an exclusive Agency, and the name and location of any adjacent basins. 1-10:1-11 1.2.1 1-3:1-5 The entire Eastern San Joaquin GSP consists of GSAs that are exclusive GSAs. This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 2 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(2) Adjudicated areas, other Agencies within the basin, and areas covered by an Alternative. 1-11 1.2.1.1
There are no adjudicated areas within the Eastern
San Joaquin GSP nor was an alternative plan prepared. This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(3)
Jurisdictional boundaries of federal or state land (including the identity of the agency with jurisdiction over that land), tribal land, cities, counties, agencies with water management responsibilities, and areas covered by relevant general plans. 1-11:1-23 1.2.1.1
1-6:1-7, 1-11
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(4) Existing land use designations and the identification of water use sector and water source type. 1-11:1-23 1.2.1.1 1-9:1-10
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(5)
The density of wells per square mile, by dasymetric or similar mapping techniques, showing the general distribution of agricultural, industrial, and domestic water supply wells in the basin, including de minimis extractors, and the location and extent of communities dependent upon groundwater, utilizing data provided by the Department, as specified in Section 353.2, or the best available information. 1-21:1-23,
1-44:1-45,XX:X-X

1.2.1.1, 1.3.1, Appendix 1-E 1-12:1-14
This field was updated to reflect changes made in the Revised GSP, updated June 2022. Pages ____ references Appendix 1-E. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024. (b) A written description of the Plan area, including a summary of the jurisdictional areas and other features depicted on the map. 1-11:1-23 1.2.1
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(c)
Identification of existing water resource monitoring and management programs, and description of any such programs the Agency plans to incorporate in its monitoring network or in development of its Plan. The Agency may coordinate with existing water resource monitoring and management programs to incorporate and adopt that program as part of the Plan. 1-23:1-25 1.2.2 1-15:1-16
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(d)
A description of how existing water resource monitoring or management programs may limit operational flexibility in the basin, and how the Plan has been developed to adapt to those limits.
1-23:1-35 1.2.2
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 3 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(e) A description of conjunctive use programs in the basin. 1-34:1-35 1.2.2.9 1-16
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(f) A plain language description of the land use elements or topic categories of applicable general plans that includes the following:
(1) A summary of general plans and other land use plans governing the basin. 1-35:1-38 1.2.3.1
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2)
A general description of how implementation of existing land use plans may change water demands within the basin or affect the ability of the Agency to achieve sustainable groundwater management over the planning and implementation horizon, and how the Plan addresses those potential effects 1-35:1-38

1.2.3.1:1.2. 3.3
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(3) A general description of how implementation of the Plan may affect the water supply assumptions of relevant land use plans over the planning and implementation horizon. 1-37:1-38 1.2.3.2
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(4)
A summary of the process for permitting new or replacement wells in the basin, including adopted standards in local well ordinances, zoning codes, and policies contained in adopted land use plans. 1-38:1-42 1.2.3.4 1-1:1-3
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(5)
To the extent known, the Agency may include information regarding the implementation of land use plans outside the basin that could affect the ability of the Agency to achieve sustainable groundwater management. 1-38 1.2.3.3
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(g) A description of any of the additional Plan elements included in Water Code Section 10727.4 that the Agency determines to be appropriate. 1-42:1-44 1.2.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Note: Authority cited: Section 10733.2, Water Code. Reference: Sections 10720.3, 10727.2, 10727.4, 10733, and 10733.2, Water Code. § 354.10. Notice and Communication

Page 4 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page Or Section Numbers Numbers of Plan Or Figure Numbers Or Table Numbers Notes Each Plan shall include a summary of information relating to notification and communication by the Agency with other agencies and interested parties including the following:
(a)
A description of the beneficial uses and users of groundwater in the basin, including the land uses and property interests potentially affected by the use of groundwater in the basin, the types of parties representing those interests, and the nature of consultation with those parties. 1-44:1-57 1.3.1:1.3.5 This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(b) A list of public meetings at which the Plan was discussed or considered by the Agency. 1-45:1-46 1.3.2
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(c) Comments regarding the Plan received by the Agency and a summary of any responses by the Agency. 1-51:1-57,XX:X-X,X-X:XX

1.3.4.2.4:1. 3.4.2.6, Appendix 1-I, Appendix 1-J
Appendix 1-I provides public comments received on the Public Draft GSP; Appendix 1-J summarizes Eastern San Joaquin Groundwater Authority responses. This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024. Pages ___ reference Appendix 1-I, and pages ____ reference Appendix 1-J. (d) A communication section of the Plan that includes the following:
(1) An explanation of the Agency’s decision-making process. 1-46 1.3.3
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2) Identification of opportunities for public engagement and a discussion of how public input and response will be used. 1-46:1-57 1.3.4 1-4:1-5
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(3) A description of how the Agency encourages the active involvement of diverse social, cultural, and economic elements of the population within the basin. 1-46:1-57 1.3.4 1-4:1-5
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 5 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(4) The method the Agency shall follow to inform the public about progress implementing the Plan, including the status of projects and actions. 1-51:1-57, 6-54

1.3.4.2, 6.2.7 1-5
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.

Note: Authority cited: Section 10733.2, Water Code. Reference: Sections 10723.2, 10727.8, 10728.4, and 10733.2, Water Code SubArticle 2. Basin Setting
§ 354.12. Introduction to Basin Setting
This Subarticle describes the information about the physical setting and characteristics of the basin and current conditions of the basin that shall be part of each Plan, including the identification of data gaps and levels of uncertainty, which comprise the basin setting that serves as the basis for defining and assessing reasonable sustainable management criteria and projects and management actions. Information provided pursuant to this Subarticle shall be prepared by or under the direction of a professional geologist or professional engineer. Note: Authority cited: Section 10733.2, Water Code. Reference: Section 10733.2, Water Code. § 354.14. Hydrogeologic Conceptual Model
(a)
Each Plan shall include a descriptive hydrogeologic conceptual model of the basin based on technical studies and qualified maps that characterizes the physical components and interaction of the surface water and groundwater systems in the basin. 2-10:2-80 2.1
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(b) The hydrogeologic conceptual model shall be summarized in a written description that includes the following:
(1) The regional geologic and structural setting of the basin including the immediate surrounding area, as necessary for geologic consistency. 2-18:2-20 2.1.2:2.1.3 2-6
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2) Lateral basin boundaries, including major geologic features that significantly affect groundwater flow. 2-20:2-58 2.1.4:2.1.8 2-7:2-29
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 6 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(3) The definable bottom of the basin.
2-58 2.1.8.2 2-20
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(4) Principal aquifers and aquitards, including the following information:
(A) Formation names, if defined.
2-40:2-42 2.1.5.1
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(B)
Physical properties of aquifers and aquitards, including the vertical and lateral extent, hydraulic conductivity, and storativity, which may be based on existing technical studies or other best available information. 2-58:2-78 2.1.9 2-30:2-41 2-3
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(C)
Structural properties of the basin that restrict groundwater flow within the principal aquifers, including information regarding stratigraphic changes, truncation of units, or other features. 2-35:2-45, 2-58:2-78

2.1.5:2.1.6, 2.1.9 2-19 2-2
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(D) General water quality of the principal aquifers, which may be based on information derived from existing technical studies or regulatory programs. 2-69:2-78 2.1.9.2.3 2-34:2-41
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(E) Identification of the primary use or uses of each aquifer, such as domestic, irrigation, or municipal water supply. 2-58:2-78 2.1.9 2:30:2-31
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(5) Identification of data gaps and uncertainty within the hydrogeologic conceptual model 2-79:2-80 2.1.10
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(c)
The hydrogeologic conceptual model shall be represented graphically by at least two scaled cross-sections that display the information required by this section and are sufficient to depict major stratigraphic and structural features in the basin. 2-46:2-57 2.1.7 2-21:2-29
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 7 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(d) Physical characteristics of the basin shall be represented on one or more maps that depict the following:
(1) Topographic information derived from the U.S. Geological Survey or another reliable source.
2-20 2.1.4.1 2-7
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2) Surficial geology derived from a qualified map including the locations of cross-sections required by this Section. 2-35:2-42 2.1.5
2-18, 2-21, 2-25, 2-13 2-2
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(3) Soil characteristics as described by the appropriate Natural Resources Conservation Service soil survey or other applicable studies. 2-26:2-29 2.1.4.3 2-10:2-12
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(4)
Delineation of existing recharge areas that substantially contribute to the replenishment of the basin, potential recharge areas, and discharge areas, including significant active springs, seeps, and wetlands within or adjacent to the basin. 2-30:2-35, 1-34

2.1.4.5, 1.2.2.9
2-13:2-14, 1-16
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(5) Surface water bodies that are significant to the management of the basin. 2-20:2-25 2.1.4.2 2-8:2-9 2-1
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(6) The source and point of delivery for imported water supplies. 2-30 2.1.4.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Note: Authority cited: Section 10733.2, Water Code.

Reference: Sections 10727.2, 10733, and 10733.2, Water Code. § 354.16. Groundwater Conditions
Each Plan shall provide a description of current and historical groundwater conditions in the basin, including data from January 1, 2015, to current conditions, based on the best available information that includes the following:
(a) Groundwater elevation data demonstrating flow directions, lateral and vertical gradients, and regional pumping patterns, including:

Page 8 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(1)
Groundwater elevation contour maps depicting the groundwater table or potentiometric surface associated with the current seasonal high and seasonal low for each principal aquifer within the basin. 2-80:2-98, 2-134:2-137 2.2.1, 2.3.1
2-45:2-46, 2-84:2-86
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2) Hydrographs depicting long-term groundwater elevations, historical highs and lows, and hydraulic gradients between principal aquifers. 2-83,2-84, 2-91:2-98 2.2.1, Appendix 3- I
2-42:2-43, 2-48:2-63
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(b)
A graph depicting estimates of the change in groundwater in storage, based on data, demonstrating the annual and cumulative change in the volume of groundwater in storage between seasonal high groundwater conditions, including the annual groundwater use and water year type. 2-99:2-100, 2-139:2-140 2.2.2, 2.3.2
2-64:2-65,2-
89 This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(c) Seawater intrusion conditions in the basin, including maps and cross-sections of the seawater intrusion front for each principal aquifer. 2-101,2-140:2-144 2.2.3, 2.3.3 2-91 2-12
Seawater intrusion is not considered an applicable sustainability indicator for the Eastern San Joaquin Subbasin as the Subbasin is not in a coastal area and seawater intrusion is not currently present and is not reasonably expected to occur due to the active management of the ‘X2’ salinity barrier by the State. This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(d)
Groundwater quality issues that may affect the supply and beneficial uses of groundwater, including a description and map of the location of known groundwater contamination sites and plumes. 2-101:2-122,2-144:2-147 2.2.4, 2.3.4
2-66:2-76, 2-92:2-94 2-5:2-11
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(e)
The extent, cumulative total, and annual rate of land subsidence, including maps depicting total subsidence, utilizing data available from the Department, as specified in Section 353.2, or the best available information. 2-122:2-123,2-147:2-155 2.2.5, 2.3.5
2-78, 2:95:2-101
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 9 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(f)
Identification of interconnected surface water systems within the basin and an estimate of the quantity and timing of depletions of those systems, utilizing data available from the Department, as specified in Section 353.2, or the best available information. 2-123:2-126,2-155:2-161 2.2.6, 2.3.6
2-79:2-80, 2-102:2-105
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(g)
Identification of groundwater dependent ecosystems within the basin, utilizing data available from the Department, as specified in Section 353.2, or the best available information. 2-126:2- 133, 2-163 2.2.7, 2.3.7
2-81:2-83, 2-106
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Note: Authority cited: Section 10733.2, Water Code. Reference: Sections 10723.2, 10727.2, 10727.4, and 10733.2, Water Code. § 354.18. Water Budget
(a)
Each Plan shall include a water budget for the basin that provides an accounting and assessment of the total annual volume of groundwater and surface water entering and leaving the basin, including historical, current and projected water budget conditions, and the change in the volume of water stored. Water budget information shall be reported in tabular and graphical form.
2-163:2-217 2.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(b) The water budget shall quantify the following, either through direct measurements or estimates based on data:
(1) Total surface water entering and leaving a basin by water source type. 2-173:2-195 2.4.5
2-109:2-120 2-14:2-19
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2)
Inflow to the groundwater system by water source type, including subsurface groundwater inflow and infiltration of precipitation, applied water, and surface water systems, such as lakes, streams, rivers, canals, springs and conveyance systems. 2-173:2- 195 2.4.5
2-109:2-120 2-14:2-19
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(3)
Outflows from the groundwater system by water use sector, including evapotranspiration, groundwater extraction, groundwater discharge to surface water sources, and subsurface groundwater outflow. 2-173:2- 195 2.4.5
2-109:2-120 2-14:2-19
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(4) The change in the annual volume of groundwater in storage between seasonal high conditions. 2-99:2-100, 2-139:2- 140, 2- 173:2-195

2.2.2, 2.3.2,

2.4.5 2-64:2-65,
2-89, 2-
111,2-114,2-117, 2-120 2-16:2-19
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 10 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(5)
If overdraft conditions occur, as defined in Bulletin 118, the water budget shall include a quantification of overdraft over a period of years during which water year and water supply conditions approximate average conditions. 2-181:2-
184, 2-188:2-191, 2-191:2-195

2.4.5.1, 2.4.5.3, 2.4.5.4 2-17:2-19
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(6) The water year type associated with the annual supply, demand, and change in groundwater stored. 2-181:2- 184, 2- 188:2-195

2.4.5.1, 2.4.5.3, 2.4.5.4 2-17:2-19
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(7) An estimate of sustainable yield for the basin. 2-195:2- 201, 2-201:2-205 2.4.6, 2.4.7
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(c) Each Plan shall quantify the current, historical, and projected water budget for the basin as follows:
(1)
Current water budget information shall quantify current inflows and outflows for the basin using the most recent hydrology, water supply, water demand, and land use information. 2-170, 2- 185:2-187

2.4.4.2, 2.4.5.2
2-112:2-114
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2)
Historical water budget information shall be used to evaluate availability or reliability of past surface water supply deliveries and aquifer response to water supply and demand trends relative to water year type. The historical water budget shall include the following:
(A)
A quantitative evaluation of the availability or reliability of historical surface water supply deliveries as a function of the historical planned versus actual annual surface water deliveries, by surface water source and water year type, and based on the most recent ten years of surface water supply information. 2-168:2-170, 2-181:2-184

2.4.4.1, 2.4.5.1
2-109:2-111 2-17
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(B)
A quantitative assessment of the historical water budget, starting with the most recently available information and extending back a minimum of 10 years, or as is sufficient to calibrate and reduce the uncertainty of the tools and methods used to estimate and project future water budget information and future aquifer response to proposed sustainable groundwater management practices over the planning and implementation horizon.
2-168:2-170, 2-181:2-184

2.4.4.1, 2.4.5.1
2-109:2-111 2-17
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(C)
A description of how historical conditions concerning hydrology, water demand, and surface water supply availability or reliability have impacted the ability of the Agency to operate the basin within sustainable yield. Basin hydrology may be characterized and evaluated using water year type. 2-165:2-166 2.4.2 2-108
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 11 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page Or Section Numbers Numbers of Plan Or Figure Numbers Or Table Numbers Notes (3)
Projected water budgets shall be used to estimate future baseline conditions of supply, demand, and aquifer response to Plan implementation, and to identify the uncertainties of these projected water budget components. The projected water budget shall utilize the following methodologies and assumptions to estimate future baseline conditions concerning hydrology, water demand and surface water supply availability or reliability over the planning and implementation horizon:
2-165:2-
166, 2-170:2-172,
Projected hydrology shall utilize 50 years of historical precipitation, evapotranspiration, 2-188:2-and streamflow information as the baseline condition for estimating future hydrology. 191, 2- (A) The projected hydrology information shall also be applied as the baseline condition used 195:2- 201,2- to evaluate future scenarios of hydrologic uncertainty associated with projections of 201:2- 2.4.2, climate change and sea level rise. 205,2- 2.4.4.3, This field was updated to reflect changes made in 205:2- 2.4.5.3, the Revised GSP, updated June 2022. This field 212,2- 2.4.6, 2.4.7, 2-108, 2- 2-13, 2- was updated again to reflect changes made in the 212:2-217 2.4.8, 2.4.9 115:2-132 20:2-28 2024 GSP Amendment, updated November 2024. 2-170:2-
172, 2-
Projected water demand shall utilize the most recent land use, evapotranspiration, and 188:2-191, crop coefficient information as the baseline condition for estimating future water 2-195:2- (B) demand. The projected water demand information shall also be applied as the baseline 201,2- 201:2- condition used to evaluate future scenarios of water demand uncertainty associated with 205,2- 2.4.4.3, This field was updated to reflect changes made in projected changes in local land use planning, population growth, and climate. 205:2- 2.4.5.3, the Revised GSP, updated June 2022. This field 212,2- 2.4.6, 2.4.7, 2-115:2- was updated again to reflect changes made in the 212:2-217 2.4.8, 2.4.9 132 2-20:2-28 2024 GSP Amendment, updated November 2024. 2-165:2-
166, 2-170:2-172,
Projected surface water supply shall utilize the most recent water supply information as 2-188:2-the baseline condition for estimating future surface water supply. The projected surface 191, 2- (C) water supply shall also be applied as the baseline condition used to evaluate future 195:2- scenarios of surface water supply availability and reliability as a function of the historical 201,2- surface water supply identified in Section 354.18(c)(2)(A), and the projected changes in 201:2- 2.4.2, local land use planning, population growth, and climate. 205,2- 2.4.4.3, This field was updated to reflect changes made in 205:2- 2.4.5.3, the Revised GSP, updated June 2022. This field 212,2- 2.4.6, 2.4.7, 2-115:2- 2-13, 2- was updated again to reflect changes made in the 212:2-217 2.4.8, 2.4.9 132 20:2-28 2024 GSP Amendment, updated November 2024.

Page 12 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page Or Section Numbers Numbers of Plan Or Figure Numbers Or Table Numbers Notes (d)
The Agency shall utilize the following information provided, as available, by the Department pursuant to Section 353.2, or other data of comparable quality, to develop the water budget:

Historical water budget information for mean annual temperature, mean annual This field was updated to reflect changes made in (1) precipitation, water year type, and land use. 2-165:2- the Revised GSP, updated June 2022. This field 166,2- 2.4.2, was updated again to reflect changes made in the 168:2-170 2.4.4.1 2-108 2024 GSP Amendment, updated November 2024.

Current water budget information for temperature, water year type, evapotranspiration, This field was updated to reflect changes made in (2) and land use. 2-165:2- the Revised GSP, updated June 2022. This field 166,2- 2.4.2, was updated again to reflect changes made in the 168:2-170 2.4.4.2 2-108 2024 GSP Amendment, updated November 2024. 2-170:2-
172, 2-188:2-191, 2-195:2-
Projected water budget information for population, population growth, climate change, 201,2- (3) and sea level rise. 201:2- 205,2- 2.4.4.3, This field was updated to reflect changes made in 205:2- 2.4.5.3, the Revised GSP, updated June 2022. This field 212,2- 2.4.6, 2.4.7, was updated again to reflect changes made in the 212:2-217 2.4.8, 2.4.9 2024 GSP Amendment, updated November 2024. (e)
Each Plan shall rely on the best available information and best available science to quantify the water budget for the basin in order to provide an understanding of historical and projected hydrology, water demand, water supply, land use, population, climate change, sea level rise, groundwater and surface water interaction, and subsurface groundwater flow. If a numerical groundwater and surface water model is not used to quantify and evaluate the projected water budget conditions and the potential impacts to beneficial uses and users of groundwater, the Plan shall identify and describe an equally effective method, tool, or analytical model to evaluate projected water budget conditions.
2-163:2-165, 2-166:2-167, X-X:X-X

2.4.1, 2.4.3,
Appendix 2-
A:2-C
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.Pages ____reference Appendix 2-A:2-C: Eastern San Joaquin Water Resources Model reports. (f)
The Department shall provide the California Central Valley Groundwater-Surface Water Simulation Model (C2VSIM) and the Integrated Water Flow Model (IWFM) for use by Agencies in developing the water budget. Each Agency may choose to use a different groundwater and surface water model, pursuant to Section 352.4. 2-163:2-165, 2-166:2-167, X-X:X-X

Note: Authority cited: Section 10733.2, Water Code.

Page 13 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
Reference: Sections 10721, 10723.2, 10727.2, 10727.6, 10729, and 10733.2, Water Code. § 354.20. Management Areas
(a)
Each Agency may define one or more management areas within a basin if the Agency has determined that creation of management areas will facilitate implementation of the Plan. Management areas may define different minimum thresholds and be operated to different measurable objectives than the basin at large, provided that undesirable results are defined consistently throughout the basin. N/A No management areas have been identified for the Eastern San Joaquin Subbasin. (b) A basin that includes one or more management areas shall describe the following in the Plan:
(1) The reason for the creation of each management area.

N/A
No management areas have been identified for the Eastern San Joaquin Subbasin. (2)
The minimum thresholds and measurable objectives established for each management area, and an explanation of the rationale for selecting those values, if different from the basin at large. N/A
No management areas have been identified for the Eastern San Joaquin Subbasin. (3) The level of monitoring and analysis appropriate for each management area.

N/A
No management areas have been identified for the Eastern San Joaquin Subbasin. (4)
An explanation of how the management area can operate under different minimum thresholds and measurable objectives without causing undesirable results outside the management area, if applicable. N/A
No management areas have been identified for the Eastern San Joaquin Subbasin. (c)
If a Plan includes one or more management areas, the Plan shall include descriptions, maps, and other information required by this Subarticle sufficient to describe conditions in those areas. N/A
No management areas have been identified for the Eastern San Joaquin Subbasin.

Note: Authority cited: Section 10733.2, Water Code. Reference: Sections 10733.2 and 10733.4, Water Code.

SubArticle 3. Sustainable Management Criteria
§ 354.22. Introduction to Sustainable Management Criteria This Subarticle describes criteria by which an Agency defines conditions in its Plan that constitute sustainable groundwater management for the basin, including the process by which the Agency shall characterize undesirable results, and establish minimum thresholds and measurable objectives for each applicable sustainability indicator.

Note: Authority cited: Section 10733.2, Water Code. Reference: Section 10733.2, Water Code. § 354.24. Sustainability Goal

Page 14 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page Or Section Numbers Numbers of Plan Or Figure Numbers Or Table Numbers Notes Each Agency shall establish in its Plan a sustainability goal for the basin that culminates in the absence of undesirable results within 20 years of the applicable statutory deadline. The Plan shall include a description of the sustainability goal, including information from the basin setting used to establish the sustainability goal, a discussion of the measures that will be implemented to ensure that the basin will be operated within its sustainable yield, and an explanation of how the sustainability goal is likely to be achieved within 20 years of Plan implementation and is likely to be maintained through the planning and implementation horizon. 1-2,3-1:3-2 1.1.2, 3.1 This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Note: Authority cited: Section 10733.2, Water Code. Reference: Sections 10721, 10727, 10727.2, 10733.2, and 10733.8, Water Code. § 354.26. Undesirable Results

3.3.1.1.1,

3.3.1.1.2, 3.3.2.1.1,
Each Agency shall describe in its Plan the processes and criteria relied upon to define 3.3.2.1.2, undesirable results applicable to the basin. Undesirable results occur when significant 3.3.3.1.1, (a) and unreasonable effects for any of the sustainability indicators are caused by 3.3.3.1.2, 3-3:3-5, 3- 3.3.4, groundwater conditions occurring throughout the basin. 13:3-14, 3- 3.3.5.1.1, This field was updated to reflect changes made in 15:3-16, 3- 3.3.5.1.2, the Revised GSP, updated June 2022. This field 23, 3-23:3- 3.3.6.1.1, was updated again to reflect changes made in the 25,3-28 3.3.6.1.2 2024 GSP Amendment, updated November 2024. (b) The description of undesirable results shall include the following:

The cause of groundwater conditions occurring throughout the basin that would lead to

3.3.1.1.3,

3.3.2.1.3, 3.3.3.1.3,
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field 3-5,3-13:3- 3.3.4, was updated again to reflect changes made in the (1) or has led to undesirable results based on information described in the basin setting, and 14,3-15:3- 3.3.5.1.3, 2024 GSP Amendment, updated November 2024. other data or models as appropriate. 16,3-23,3- 3.3.6.1.3, Pages ___ reference to Appendix 3-E Technical 25:3-26,3- Appendix 3- Memorandum No. 4 - Water Budgets and 28,X-X:X-X E Groundwater Storage.

3.3.1.1.2,
The criteria used to define when and where the effects of the groundwater conditions 3.3.2.1.2, cause undesirable results for each applicable sustainability indicator. The criteria shall be 3-4:3-5, 3- 3.3.3.1.2, This field was updated to reflect changes made in (2) based on a quantitative description of the combination of minimum threshold 13:3-14, 3- 3.3.4, the Revised GSP, updated June 2022. This field exceedances that cause significant and unreasonable effects in the basin. 16, 3-23, 3- 3.3.5.1.2, was updated again to reflect changes made in the 25, 3-28 3.3.6.1.2 2024 GSP Amendment, updated November 2024.

Page 15 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(3)
Potential effects on the beneficial uses and users of groundwater, on land uses and property interests, and other potential effects that may occur or are occurring from undesirable results. 3-5, 3-14, 3-16, 3-23, 3-26, 3-28:3-29

3.3.1.1.4,

3.3.2.1.4, 3.3.3.1.4, 3.3.4, 3.3.5.1.4, 3.3.6.1.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(c)
The Agency may need to evaluate multiple minimum thresholds to determine whether an undesirable result is occurring in the basin. The determination that undesirable results are occurring may depend upon measurements from multiple monitoring sites, rather than a single monitoring site. 3-5:3-10, 3-
14:3-15, 3-17:3-20, 3-23, 3-26:3-27, 3-29:3-31

3.3.1.2,

3.3.2.2, 3.3.3.2, 3.3.4, 3.3.5.2, 3.3.6.2
3-2, 3-3, 3-5, 3-6
3-1, 3-4, 3-7
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(d)
An Agency that is able to demonstrate that undesirable results related to one or more sustainability indicators are not present and are not likely to occur in a basin shall not be required to establish criteria for undesirable results related to those sustainability indicators. N/A
The Eastern San Joaquin GSP establishes minimum thresholds for each of the six sustainability indicators.

Note: Authority cited: Section 10733.2, Water Code.

Reference: Sections 10721, 10723.2, 10727.2, 10733.2, and 10733.8, Water Code. § 354.28. Minimum Thresholds
(a)
Each Agency in its Plan shall establish minimum thresholds that quantify groundwater conditions for each applicable sustainability indicator at each monitoring site or representative monitoring site established pursuant to Section 354.36. The numeric value used to define minimum thresholds shall represent a point in the basin that, if exceeded, may cause undesirable results as described in Section 354.26. 3-5:3-10, 3-14:3-15, 3-17:3-20, 3-23, 3-26:3-27, 3-29:3-31

3.3.1.2, 3.3.2.2, 3.3.3.2, 3.3.4, 3.3.5.2, 3.3.6.2 3-2:3-6 3-1, 3-4, 3-
7 This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(b) The description of minimum thresholds shall include the following:
(1)
The information and criteria relied upon to establish and justify the minimum thresholds for each sustainability indicator. The justification for the minimum threshold shall be supported by information provided in the basin setting, and other data or models as appropriate, and qualified by uncertainty in the understanding of the basin setting. 3-5:3-10, 3-
14:3-15, 3-17:3-20, 3-23, 3-26:3-27, 3-29:3-31

3.3.1.2,

3.3.2.2, 3.3.3.2, 3.3.4, 3.3.5.2, 3.3.6.2 3-2:3-6
3-1, 3-4, 3-7
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2)
The relationship between the minimum thresholds for each sustainability indicator, including an explanation of how the Agency has determined that basin conditions at each minimum threshold will avoid undesirable results for each of the sustainability indicators. 3-5:3-10, 3-
14:3-15, 3-17:3-20, 3-23, 3-26:3-27, 3-29:3-31

3.3.1.2,

3.3.2.2, 3.3.3.2, 3.3.4.2, 3.3.5.2, 3.3.6.2 3-2:3-6
3-1, 3-4, 3-7
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 16 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
3-5:3-10, 3- 3.3.1.2,
14:3-15, 3- 3.2.2.2,
How minimum thresholds have been selected to avoid causing undesirable results in 17:3-20, 3- 3.3.3.2, This field was updated to reflect changes made in (3) adjacent basins or affecting the ability of adjacent basins to achieve sustainability goals. 23, 3-26:3- 3.3.4.2, the Revised GSP, updated June 2022. This field 27, 3-29:3- 3.3.5.2, 3-1, 3-4, 3- was updated again to reflect change made in the 31 3.3.6.2 3-2:3-6 7 2024 GSP Amendment, updated November 2024. 3-5:3-10, 3- 3.3.1.2,
14:3-15, 3- 3.3.2.2,
How minimum thresholds may affect the interests of beneficial uses and users of 17:3-20, 3- 3.3.3.2, This field was updated to reflect changes made in (4) groundwater or land uses and property interests. 23, 3-26:3- 3.3.4.2, the Revised GSP, updated June 2022. This field 27, 3-29:3- 3.3.5.2, 3-1, 3-4, 3- was updated again to reflect change made in the 31 3.3.6.2 3-2:3-6 7 2024 GSP Amendment, updated November 2024. 3-5:3-10, 3- 3.3.1.2,
How state, federal, or local standards relate to the relevant sustainability indicator. If the 14:3-15, 3- 3.3.2.2, 17:3-20, 3- 3.3.3.2, This field was updated to reflect changes made in (5) minimum threshold differs from other regulatory standards, the Agency shall explain the 23, 3-26:3- 3.3.4.2, the Revised GSP, updated June 2022. This field nature of and basis for the difference. 27, 3-29:3- 3.3.5.2, 3-1, 3-4, 3- was updated again to reflect changes made in the 31 3.3.6.2 3-2:3-6 7 2024 GSP Amendment, updated November 2024. 3-5:3-10, 3- 3.3.1.2,
14:3-15, 3- 3.3.2.2,
How each minimum threshold will be quantitatively measured, consistent with the 17:3-20, 3- 3.3.3.2, (6) monitoring network requirements described in Subarticle 4. 23, 3-26:3- 3.3.4.2, This field was updated to reflect changes made in 27, 3-29:3- 3.3.5.2, the Revised GSP, updated June 2022. This field 31, 4-1:4- 3.3.6.2, 3-1, 3-4, 3- was updated again to reflect changes made in the 21 4.1:4.6 3-2:3-6 7, 4-1:4-8 2024 GSP Amendment, updated November 2024. (c) Minimum thresholds for each sustainability indicator shall be defined as follows:
(1)
Chronic Lowering of Groundwater Levels. The minimum threshold for chronic lowering of groundwater levels shall be the groundwater elevation indicating a depletion of supply at a given location that may lead to undesirable results. Minimum thresholds for chronic lowering of groundwater levels shall be supported by the following:
(A) The rate of groundwater elevation decline based on historical trends, water year type, and projected water use in the basin. 2-80:2-98,2- 134:2- 139,2- 163:2-217, 3-5:3-10,XX:X-X,X-X:XX

2.2.1, 2.3.1, 2.4, 3.3.1.2,
Appendix 3-
H:3-I, Appendix 3-C 2-42:2-43
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024. Pages __ and pages __ reference Appendix 3H Supplemental Data for Chronic Lowering of Groundwater Level Minimum Thresholds and Appendix 3-I Groundwater Level Representative Monitoring Well Historical Hydrographs.

Page 17 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers Or Section Or Figure Or Table Notes Numbers Numbers Numbers of Plan This field was updated to reflect changes made in
(B) Potential effects on other sustainability indicators. the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
3-3:3-12 3.3.1 2024 GSP Amendment, updated November 2024.

Reduction of Groundwater Storage. The minimum threshold for reduction of groundwater storage shall be a total volume of groundwater that can be withdrawn from (2) the basin without causing conditions that may lead to undesirable results. Minimum thresholds for reduction of groundwater storage shall be supported by the sustainable yield of the basin, calculated based on historical trends, water year type, and projected 3-14:3-15,

3.3.2.2, Appendix 3-
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the water use in the basin. X-X:X-X E 2024 GSP Amendment, updated November 2024. Seawater Intrusion. The minimum threshold for seawater intrusion shall be defined by a (3) chloride concentration isocontour for each principal aquifer where seawater intrusion may lead to undesirable results. Minimum thresholds for seawater intrusion shall be supported by the following:

Seawater intrusion is not considered an applicable sustainability indicator for the Eastern San Joaquin Subbasin as the Subbasin is not in a coastal area and seawater intrusion is not (A) Maps and cross-sections of the chloride concentration isocontour that defines the minimum threshold and measurable objective for each principal aquifer. currently present and is not reasonably expected to occur due to the active management of the ‘X2’ salinity barrier by the State.
3-23, X-X:XX

3.3.4, Appendix 3-F
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.

Page 18 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(B) A description of how the seawater intrusion minimum threshold considers the effects of current and projected sea levels. 3-23, X-X:XX

3.3.4, Appendix 3-F
Seawater intrusion is not considered an applicable sustainability indicator for the Eastern San Joaquin Subbasin as the Subbasin is not in a coastal area and seawater intrusion is not currently present and is not reasonably expected to occur due to the active management of the ‘X2’ salinity barrier by the State. This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(4)
Degraded Water Quality. The minimum threshold for degraded water quality shall be the degradation of water quality, including the migration of contaminant plumes that impair water supplies or other indicator of water quality as determined by the Agency that may lead to undesirable results. The minimum threshold shall be based on the number of supply wells, a volume of water, or a location of an isocontour that exceeds concentrations of constituents determined by the Agency to be of concern for the basin. In setting minimum thresholds for degraded water quality, the Agency shall consider local, state, and federal water quality standards applicable to the basin. 3-17:3-20,2-
101:2-122,2-144:2-147,X-X:X-X

3.3.3.2,

2.2.4, 2.3.4,
Appendix 3-
F
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(5)
Land Subsidence. The minimum threshold for land subsidence shall be the rate and extent of subsidence that substantially interferes with surface land uses and may lead to undesirable results. Minimum thresholds for land subsidence shall be supported by the following:
(A)
Identification of land uses and property interests that have been affected or are likely to be affected by land subsidence in the basin, including an explanation of how the Agency has determined and considered those uses and interests, and the Agency’s rationale for establishing minimum thresholds in light of those effects. 3-25:3-27 3.3.5.2 3-4:3-5 This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(B) Maps and graphs showing the extent and rate of land subsidence in the basin that defines the minimum threshold and measurable objectives. 3-23:3-28,2- 122:2-123, 2-147:2-155,X-X:X-X

3.3.5, 2.2.5,

2.3.5 Appendix 3-
D 3-4
This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.

Page 19 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page Or Section Numbers Numbers of Plan Or Figure Numbers Or Table Numbers Notes (6)
Depletions of Interconnected Surface Water. The minimum threshold for depletions of interconnected surface water shall be the rate or volume of surface water depletions caused by groundwater use that has adverse impacts on beneficial uses of the surface water and may lead to undesirable results. The minimum threshold established for depletions of interconnected surface water shall be supported by the following:
(A) The location, quantity, and timing of depletions of interconnected surface water. 3-28:3-32, 2-123:2-126, 2-155:2-161

3.3.6, 2.2.6,

2.3.6 2-103, 2-105
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(B)
A description of the groundwater and surface water model used to quantify surface water depletion. If a numerical groundwater and surface water model is not used to quantify surface water depletion, the Plan shall identify and describe an equally effective method, tool, or analytical model to accomplish the requirements of this Paragraph. 3-29:3-31,2- 155:2-161, X-X:X-X

3.3.6.2, 2.3.6, Appendix 2-A:2-C
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024. Pages __ reference Appendix 2-A:2-C Eastern San Joaquin Water Resources Model Report (s). (d)
An Agency may establish a representative minimum threshold for groundwater elevation to serve as the value for multiple sustainability indicators, where the Agency can demonstrate that the representative value is a reasonable proxy for multiple individual minimum thresholds as supported by adequate evidence. 3-29:3-31 3.3.6.2 This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(e)
An Agency that has demonstrated that undesirable results related to one or more sustainability indicators are not present and are not likely to occur in a basin, as described in Section 354.26, shall not be required to establish minimum thresholds related to those sustainability indicators.

The Eastern San Joaquin GSP establishes minimum thresholds for each of the six sustainability indicators.

Note: Authority cited: Section 10733.2, Water Code.

Reference: Sections 10723.2, 10727.2, 10733, 10733.2, and 10733.8, Water Code. § 354.30. Measurable Objectives
(a)
Each Agency shall establish measurable objectives, including interim milestones in increments of five years, to achieve the sustainability goal for the basin within 20 years of Plan implementation and to continue to sustainably manage the groundwater basin over the planning and implementation horizon. 3-10:3-12,
3-15, 3-
20:3-22,3-27:3-28, 3-31:3-32

3.3.1.3,

3.3.2.3, 3.3.3.3, 3.3.5.3, 3.3.6.3
3-2:3-3, 3-5:3-6, 3-8
This field has been updated to reflect changes
made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024. (b)
Measurable objectives shall be established for each sustainability indicator, based on quantitative values using the same metrics and monitoring sites as are used to define the minimum thresholds. 3-10:3-12,
3-15, 3-
20:3-22,3-27:3-28, 3-31:3-32

3.3.1.3,

Page 20 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(c)
Measurable objectives shall provide a reasonable margin of operational flexibility under adverse conditions which shall take into consideration components such as historical water budgets, seasonal and long-term trends, and periods of drought, and be commensurate with levels of uncertainty. 3-10:3-12,
3-15, 3-
20:3-22,3-27:3-28, 3-31:3-32

3.3.1.3,

3.3.2.3, 3.3.3.3, 3.3.5.3, 3.3.6.3
3-2:3-3, 3-5:3-6, 3-8
This field has been updated to reflect changes
made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024. (d)
An Agency may establish a representative measurable objective for groundwater elevation to serve as the value for multiple sustainability indicators where the Agency can demonstrate that the representative value is a reasonable proxy for multiple individual measurable objectives as supported by adequate evidence. 3-10:3-12,
3-15, 3-
20:3-22,3-27:3-28, 3-31:3-32

3.3.1.3,

3.3.2.3, 3.3.3.3, 3.3.5.3, 3.3.6.3
This field was updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(e)
Each Plan shall describe a reasonable path to achieve the sustainability goal for the basin within 20 years of Plan implementation, including a description of interim milestones for each relevant sustainability indicator, using the same metric as the measurable objective, in increments of five years. The description shall explain how the Plan is likely to maintain sustainable groundwater management over the planning and implementation horizon.
3-10:3-12, 3-15, 3-20:3-22,3-27:3-28, 3-31:3-32

3.3.1.3, 3.3.2.3, 3.3.3.3, 3.3.5.3, 3.3.6.3
3-2:3-3, 3-5:3-6, 3-8
This field has been updated to reflect changes made in the Revised GSP, updated June 2022. This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024. (f)
Each Plan may include measurable objectives and interim milestones for additional Plan elements described in Water Code Section 10727.4 where the Agency determines such measures are appropriate for sustainable groundwater management in the basin. N/A Measurable objectives and interim milestones for
additional Plan elements described in Water Code Section 10727.4 have not been included, as this is optional.
(g)
An Agency may establish measurable objectives that exceed the reasonable margin of operational flexibility for the purpose of improving overall conditions in the basin, but failure to achieve those objectives shall not be grounds for a finding of inadequacy of the Plan. 3-10:3-12,
3-15, 3-
20:3-22,3-27:3-28, 3-31:3-32

3.3.1.3,

Note: Authority cited: Section 10733.2, Water Code. Reference: Sections 10727.2, 10727.4, and 10733.2, Water Code.

SubArticle 4. Monitoring Networks
§ 354.32. Introduction to Monitoring Networks
This Subarticle describes the monitoring network that shall be developed for each basin, including monitoring objectives, monitoring protocols, and data reporting requirements. The monitoring network shall promote the collection of data of sufficient quality, frequency, and distribution to characterize groundwater and related surface water conditions in the basin and evaluate changing conditions that occur through implementation of the Plan. Note: Authority cited: Section 10733.2, Water Code. Reference: Section 10733.2, Water Code. § 354.34. Monitoring Network

Page 21 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(a)
Each Agency shall develop a monitoring network capable of collecting sufficient data to demonstrate short-term, seasonal, and long-term trends in groundwater and related surface conditions, and yield representative information about groundwater conditions as necessary to evaluate Plan implementation. 4-4:4-25 4.0 This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(b)
Each Plan shall include a description of the monitoring network objectives for the basin, including an explanation of how the network will be developed and implemented to monitor groundwater and related surface conditions, and the interconnection of surface water and groundwater, with sufficient temporal frequency and spatial density to evaluate the affects and effectiveness of Plan implementation. The monitoring network objectives shall be implemented to accomplish the following:
(1) Demonstrate progress toward achieving measurable objectives described in the Plan. 4-4:4-21 4.1:4.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2) Monitor impacts to the beneficial uses or users of groundwater. 4-4:4-21 4.1:4.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(3) Monitor changes in groundwater conditions relative to measurable objectives and minimum thresholds. 4-4:4-21 4.1:4.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(4) Quantify annual changes in water budget components. 4-4:4-21 4.1:4.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(c) Each monitoring network shall be designed to accomplish the following for each sustainability indicator:
(1)
Chronic Lowering of Groundwater Levels. Demonstrate groundwater occurrence, flow directions, and hydraulic gradients between principal aquifers and surface water features by the following methods:
(A)
A sufficient density of monitoring wells to collect representative measurements through depth-discrete perforated intervals to characterize the groundwater table or potentiometric surface for each principal aquifer. 4-9:4-10 4.1.4 4-2,4-3
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 22 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(B) Static groundwater elevation measurements shall be collected at least two times per year, to represent seasonal low and seasonal high groundwater conditions. 4-9 4.1.3
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2) Reduction of Groundwater Storage. Provide an estimate of the change in annual groundwater in storage. 4-10, 3- 13:3-15, 2- 139: 2-140

4.2, 3.3.2, 2.3.2 2-89
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(3)
Seawater Intrusion. Monitor seawater intrusion using chloride concentrations, or other measurements convertible to chloride concentrations, so that the current and projected rate and extent of seawater intrusion for each applicable principal aquifer may be calculated. 4-14:4-15 4.4 This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(4)
Degraded Water Quality. Collect sufficient spatial and temporal data from each applicable principal aquifer to determine groundwater quality trends for water quality indicators, as determined by the Agency, to address known water quality issues. 4-10:4-14 4.3 4-2 4-4
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(5)
Land Subsidence. Identify the rate and extent of land subsidence, which may be measured by extensometers, surveying, remote sensing technology, or other appropriate method. 4-15:4-18 4.5 4-3 4-7
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(6)
Depletions of Interconnected Surface Water. Monitor surface water and groundwater, where interconnected surface water conditions exist, to characterize the spatial and temporal exchanges between surface water and groundwater, and to calibrate and apply the tools and methods necessary to calculate depletions of surface water caused by groundwater extractions. The monitoring network shall be able to characterize the following:
(A) Flow conditions including surface water discharge, surface water head, and baseflow contribution. 4-18:4-21,4- 22:4-25

4.6, 4.7.3:4.7.5
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(B) Identifying the approximate date and location where ephemeral or intermittent flowing streams and rivers cease to flow, if applicable. 4-18:4-21,4- 22:4-25

Page 23 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(C) Temporal change in conditions due to variations in stream discharge and regional groundwater extraction. 4-18:4-21,4- 22:4-25

4.6, 4.7.3:4.7.5
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(D) Other factors that may be necessary to identify adverse impacts on beneficial uses of the surface water. 4-18:4-21,4- 22:4-25

4.6, 4.7.3:4.7.5
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(d)
The monitoring network shall be designed to ensure adequate coverage of sustainability indicators. If management areas are established, the quantity and density of monitoring sites in those areas shall be sufficient to evaluate conditions of the basin setting and sustainable management criteria specific to that area. N/A No management areas have been identified for the Eastern San Joaquin Subbasin. (e) A Plan may utilize site information and monitoring data from existing sources as part of the monitoring network. 4-4:4-21 4.1:4.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(f)
The Agency shall determine the density of monitoring sites and frequency of measurements required to demonstrate short-term, seasonal, and long-term trends based upon the following factors:
(1) Amount of current and projected groundwater use. 4-9:4-10, 4- 14, 4-17:4-18, 4-21

4.1.4, 4.3.4,

4.5.4,4.6.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(2) Aquifer characteristics, including confined or unconfined aquifer conditions, or other physical characteristics that affect groundwater flow. 4-9:4-10, 4- 14, 4-17:4- 18, 4-21

4.1.4, 4.3.4,

4.5.4,4.6.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(3)
Impacts to beneficial uses and users of groundwater and land uses and property interests affected by groundwater production, and adjacent basins that could affect the ability of that basin to meet the sustainability goal. 4-9:4-10, 4-14, 4-17:4-18, 4-21

4.1.4, 4.3.4,

4.5.4,4.6.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.

Page 24 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(4) Whether the Agency has adequate long-term existing monitoring results or other technical information to demonstrate an understanding of aquifer response. 4-9:4-10, 4- 14, 4-17:4- 18, 4-21

4.1.4, 4.3.4,

4.5.4,4.6.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(g) Each Plan shall describe the following information about the monitoring network:
(1) Scientific rationale for the monitoring site selection process. 4-4:4-8,4-
8:4-9, 4-10,4-11:4-13, 4-13:4-14, 4-14:4-15, 4-15:4-17,4-17,4-18:4-20,4-21

4.1.1, 4.1.2,

4.2, 4.3.1, 4.3.2, 4.4,

4.5.1, 4.5.2,

4.6.1, 4.6.2
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(2)
Consistency with data and reporting standards described in Section 352.4. If a site is not consistent with those standards, the Plan shall explain the necessity of the site to the monitoring network, and how any variation from the standards will not affect the usefulness of the results obtained. 4-4:4-10, 4-
10:4-14, 4-15:4-18, 4-18:4-21, 4-21:4-25

4.1, 4.3, 4.5,4.6, 4.7
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(3)
For each sustainability indicator, the quantitative values for the minimum threshold, measurable objective, and interim milestones that will be measured at each monitoring site or representative monitoring sites established pursuant to Section 354.36. 4-4:4-25 4.0
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(h)
The location and type of each monitoring site within the basin displayed on a map, and reported in tabular format, including information regarding the monitoring site type, frequency of measurement, and the purposes for which the monitoring site is being used. 4-4:4-10, 4-
10:4-14, 4-15:4-18, 4-18:4-21, 4-21:4-25

4.1, 4.3, 4.5, 4.6, 4.7 4-1:4-4
4-1, 4-4, 4-
7:4-8
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(i)
The monitoring protocols developed by each Agency shall include a description of technical standards, data collection methods, and other procedures or protocols pursuant to Water Code Section 10727.2(f) for monitoring sites or other data collection facilities to ensure that the monitoring network utilizes comparable data and methodologies.
4-8:4-9, 4-13:4-14, 4-17, 4-21

4.1.2, 4.3.2,

4.5.2, 4.6.2
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the 2024 GSP Amendment, updated November 2024.
(j)
An Agency that has demonstrated that undesirable results related to one or more sustainability indicators are not present and are not likely to occur in a basin, as described in Section 354.26, shall not be required to establish a monitoring network related to those sustainability indicators. N/A
The Eastern San Joaquin GSP establishes minimum thresholds for each of the six sustainability indicators.

Note: Authority cited: Section 10733.2, Water Code.

Reference: Sections 10723.2, 10727.2, 10727.4, 10728, 10733, 10733.2, and 10733.8, Water Code

Page 25 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
§ 354.36. Representative Monitoring
Each Agency may designate a subset of monitoring sites as representative of conditions in the basin or an area of the basin, as follows:
(a)
Representative monitoring sites may be designated by the Agency as the point at which sustainability indicators are monitored, and for which quantitative values for minimum thresholds, measurable objectives, and interim milestones are defined. 4-4:4-8, 4-11:4-13, 4-15:4-17, 4-18:4-20

4.1.1, 4.3.1,

4.5.1,4.6.1, 4.4 4-1:4-4
4-1, 4-4, 4-7:4-8
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(b) (b) Groundwater elevations may be used as a proxy for monitoring other sustainability indicators if the Agency demonstrates the following:
(1) Significant correlation exists between groundwater elevations and the sustainability indicators for which groundwater elevation measurements serve as a proxy. 4-10 4.2
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2)
Measurable objectives established for groundwater elevation shall include a reasonable margin of operational flexibility taking into consideration the basin setting to avoid undesirable results for the sustainability indicators for which groundwater elevation measurements serve as a proxy. 3-14:3-15 3.3.2.2 This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(c) The designation of a representative monitoring site shall be supported by adequate evidence demonstrating that the site reflects general conditions in the area. 4-4:4-8 4.1.1
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Note: Authority cited: Section 10733.2, Water Code.

Reference: Sections 10727.2 and 10733.2, Water Code
§ 354.38. Assessment and Improvement of Monitoring Network (a)
Each Agency shall review the monitoring network and include an evaluation in the Plan and each five-year assessment, including a determination of uncertainty and whether there are data gaps that could affect the ability of the Plan to achieve the sustainability goal for the basin. 4-21:4-25 4.7 This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(b)
Each Agency shall identify data gaps wherever the basin does not contain a sufficient number of monitoring sites, does not monitor sites at a sufficient frequency, or utilizes monitoring sites that are unreliable, including those that do not satisfy minimum standards of the monitoring network adopted by the Agency. 4-21:4-22 4.7.1:4.7.4 This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(c) If the monitoring network contains data gaps, the Plan shall include a description of the following:

Page 26 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(1) The location and reason for data gaps in the monitoring network. 4-21:4-22 4.7.1:4.7.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2) Local issues and circumstances that limit or prevent monitoring. 4-21:4-22 4.7.1:4.7.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(d)
Each Agency shall describe steps that will be taken to fill data gaps before the next fiveyear assessment, including the location and purpose of newly added or installed monitoring sites. 4-22:4-25 4.7.5 4-5 4-9
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(e)
Each Agency shall adjust the monitoring frequency and density of monitoring sites to provide an adequate level of detail about site-specific surface water and groundwater conditions and to assess the effectiveness of management actions under circumstances that include the following:
(1) Minimum threshold exceedances.
4-4:4-25 4.0
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(2) Highly variable spatial or temporal conditions.
4-4:4-25 4.0
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(3) Adverse impacts to beneficial uses and users of groundwater. 4-4:4-25 4.0
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(4) The potential to adversely affect the ability of an adjacent basin to implement its Plan or impede achievement of sustainability goals in an adjacent basin. 4-4:4-25 4.0
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Note: Authority cited: Section 10733.2, Water Code.

Reference: Sections 10723.2, 10727.2, 10728.2, 10733, 10733.2, and 10733.8, Water Code

Page 27 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
§ 354.40. Reporting Monitoring Data to the Department
Monitoring data shall be stored in the data management system developed pursuant to Section 352.6. A copy of the monitoring data shall be included in the Annual Report and submitted electronically on forms provided by the Department.

Note: Authority cited: Section 10733.2, Water Code. Reference: Sections 10728, 10728.2, 10733.2, and 10733.8, Water Code.

SubArticle 5. Projects and Management Actions
§ 354.42. Introduction to Projects and Management Actions This Subarticle describes the criteria for projects and management actions to be included in a Plan to meet the sustainability goal for the basin in a manner that can be maintained over the planning and implementation horizon.

Note: Authority cited: Section 10733.2, Water Code. Reference: Section 10733.2, Water Code. § 354.44. Projects and Management Actions
(a)
Each Plan shall include a description of the projects and management actions the Agency has determined will achieve the sustainability goal for the basin, including projects and management actions to respond to changing conditions in the basin. 6-1:6-59 6.0 6-1:6-2 6-1:6-2
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(b) Each Plan shall include a description of the projects and management actions that include the following:
(1)
A list of projects and management actions proposed in the Plan with a description of the measurable objective that is expected to benefit from the project or management action.

The list shall include projects and management actions that may be utilized to meet interim milestones, the exceedance of minimum thresholds, or where undesirable results have occurred or are imminent. The Plan shall include the following:
(A)
A description of the circumstances under which projects or management actions shall be implemented, the criteria that would trigger implementation and termination of projects or management actions, and the process by which the Agency shall determine that conditions requiring the implementation of particular projects or management actions have occurred. 6-2:6-54 6.2.2:6.2.6 6-1:6-2
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(B)
The process by which the Agency shall provide notice to the public and other agencies that the implementation of projects or management actions is being considered or has been implemented, including a description of the actions to be taken. 6-54 6.2.7
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 28 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(2)
If overdraft conditions are identified through the analysis required by Section 354.18, the Plan shall describe projects or management actions, including a quantification of demand reduction or other methods, for the mitigation of overdraft. 6-1:6-58 6.1:6.4
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(3) A summary of the permitting and regulatory process required for each project and management action. 6-2:6-54 6.2.2:6.2.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(4) The status of each project and management action, including a time-table for expected initiation and completion, and the accrual of expected benefits. 6-2:6-54 6.2.2:6.2.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(5) An explanation of the benefits that are expected to be realized from the project or management action, and how those benefits will be evaluated. 6-2:6-54 6.2.2:6.2.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(6)
An explanation of how the project or management action will be accomplished. If the projects or management actions rely on water from outside the jurisdiction of the Agency, an explanation of the source and reliability of that water shall be included. 6-2:6-54 6.2.2:6.2.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(7) A description of the legal authority required for each project and management action, and the basis for that authority within the Agency. 6-2:6-54 6.2.2:6.2.6
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(8) A description of the estimated cost for each project and management action and a description of how the Agency plans to meet those costs. 6-2:6-54 6.2.3:6.2.6 6-1:6-2
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(9)
A description of the management of groundwater extractions and recharge to ensure that chronic lowering of groundwater levels or depletion of supply during periods of drought is offset by increases in groundwater levels or storage during other periods. 6-1:6-59 6.0
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Page 29 of 30 ends

ATTACHMENT
2 Article 5. Plan Contents for Eastern San Joaquin Basin GSP Document References Page
Numbers
of Plan
Or Section
Numbers
Or Figure
Numbers
Or Table
Numbers Notes
(c) Projects and management actions shall be supported by best available information and best available science. 6-1:6-59 6.0
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.
(d) An Agency shall take into account the level of uncertainty associated with the basin setting when developing projects or management actions. 6-1:6-59 6.0
This field was updated to reflect changes made in the Revised GSP, updated June 2022.This field was updated again to reflect changes made in the
2024 GSP Amendment, updated November 2024.

Note: Authority cited: Section 10733.2, Water Code.

Reference: Sections 10727.2, 10727.4, and 10733.2, Water Code.

Page 30 of 30 ends

ATTACHMENT
2 ATTACHMENT 2
2024
Groundwater Sustainability Plan Amendment
Complete Appendices November 2024
APPENDIX 1-E.

COMMUNITY WATER SYSTEMS
ATTACHMENT 2
Organization Water System Population Water System Connections 4N MOBILEHOME PARK 65 31A1 WINSTONS MOBILE HOME PARK 75 30ACAMPO WATER SYSTEM 231 70ALMOND PARK WATER SYSTEM 60 20ARBOR MOBILE HOME PARK WS 340 173B&G MOBILE HOME PARK LLC WS 50 22BEL AIR MOBILE ESTATE 325 117BIG WHEEL MOBILE HOME PARK 120 63CALIFORNIA WATER SERVICE - STOCKTON 175,026 44,213CAMANCHE SOUTH SHORE-EBMUD 666 448CARDOZA VILLA CORP 30 12CARIBOU MOBILE PARK PWS 180 72CASA DE AMIGOS MANUFACTURED HOUSING COMM 220 73CCWD - JENNY LIND 9,861 3,825CCWD - WALLACE 255 108CENTURY MOBILE HOME PARK 50 19CHERRY LANE TRAILER PARK 100 43CITY OF LATHROP 35,080 9,893CITY OF MODESTO - DEL RIO 1,327 402CITY OF STOCKTON 183,046 50,129CLEMENTS WATER WORKS #43 264 80COUNTRY CLUB VISTA MUTUAL WATER CO 75 31COUNTRY MANOR MHP 75 41COUNTRY SQUIRE MOBILE ESTATES & WATER SY 131 49DOUBLE L MOBILE ESTATES 320 150EL RIO MOBILE HOME PARK 60 28ELKHORN ESTATES WATER SYSTEM 234 71ENCLAVE AT THE DELTA 39 15ESCALON, CITY OF 7,362 2,521FAIRWAY ESTATES PWS CSA-18 149 45 Community Water Systems

ATTACHMENT
2 Organization Water System Population Water System Connections FARMINGTON WATER COMPANY 270 78FINNLEES TRAILER PARK 55 26FREMONT ONE 39 15GALT, CITY OF 26,536 7,687GAYLA MANOR PWS 178 54GLENWOOD MOBILE HOME PARK 100 50HANOT FOUNDATION INC 38 15HAVEN ACRES RIVER CLUB INC 100 51HAYNES BOARD & CARE HOME 41 15IL VINETO 160 83ISLANDER MARINA 150 75KING ISLAND TRAILER PARK WATER SYSTEM 236 76KNIGHTS FERRY COMM. SVC. DIST. 168 67LINDEN COUNTY WATER DISTRICT 1,784 617LITTLE POTATO SLOUGH MUTUAL 1,510 202LOCKEFORD COMMUNITY SERV. DIST. 2,500 846LOCKEFORD MOBILE HOME PARK WTR SYS 100 42LODI HOMES 39 12LODI LAKE MOBILE HOME PARK 104 54LODI, CITY OF 68,272 29,421MANTECA, CITY OF 84,625 25,967MAPACHE TRAILER PARK 275 99MARTINEZ APARTMENTS 26 9MOBILE VILLAS TRAILER PARK 130 36MOKELUMNE MOBILE SENIOR PARK 55 25MORADA ACRES WATER SYSTEM 105 32MORADA ESTATES N PWS #46 426 129MORADA ESTATES PWS 290 88MORADA MANOR WATER SYSTEM 112 34NEW HOPE LANDING GENERAL STORE 125 44NORTH OAKS MUTUAL WATER CO 234 78

ATTACHMENT
2 Organization Water System Population Water System Connections OAKDALE, CITY OF 23,235 8,291OAKWOOD LAKE WATER DISTRICT-SUBDIVISION 1,479 448OID-OAKDALE RURAL WATER SYSTEM #1 1,570 473RANCHO SAN JOAQUIN WATER SYS 172 52RIPON, CITY OF 15,979 5,134RIVERBANK, CITY OF 24,834 7,096RIVERBANK, CITY OF 24,834 7,096RIVERSIDE MOBILE HOME PARK 55 58SAHARA MOBILE COURT 300 162SAN JOAQUIN COUNTY - COLONIAL HEIGHTS 1,841 559SAN JOAQUIN COUNTY - LINCOLN VILLAGE 5,990 1,815SAN JOAQUIN COUNTY - THORNTON 964 292SAN JOAQUIN COUNTY - WILKINSON MANOR 851 258SAN JOAQUIN COUNTY-MOKELUMNE ACRES 3,802 1,152SAN JOAQUIN COUNTY-RAYMUS VILLAGE 1,086 329SAN JOAQUIN WATER WORKS #2 310 94SAN JUAN VISTA 201 72SHADED TERRACE PWS 238 72SHADY REST TRAILER COURT 120 49SPRING CREEK ESTATES PWS 119 36STOCKTON VERDE MOBILE HOME PARK 722 293SUNNY ROAD WATER SYSTEM 34 12SUNNYSIDE ESTATES WATER SYSTEM 69 21TAHAMA VILLAGE MOBILE HOME PARK 200 68TWIN CYPRESS MOBILE HOME PARK 112 45TWIN OAKS MOBILE PARK 238 85V & P TRAILER COURT WATER SYSTEM 35 15VALLEY SPRINGS PUD 900 263VILLA CEREZOS 200 82WALNUT ACRES 106 32WAYSIDE MOTEL APARTMENTS WTR SYS 70 25

ATTACHMENT
2 Organization Water System Population Water System Connections WILKINSON MANOR A-ZONE PWS 125 38WINE COUNTRY APARTMENTS 40 16WOODBRIDGE MOBILE ESTATES 110 37

ATTACHMENT
2 APPENDIX 1-F.

RELEVANT GENERAL PLAN GOALS AND POLICIES
2024
Groundwater Sustainability Plan Amendment
Complete Appendices November 2024
ATTACHMENT 2
San Joaquin County General Plan
The abbreviations following each policy and program refer to the types of tools or actions the County can use to carry out the policies. There are eight types of tools and actions, listed below.

1. Regulation and Development Review (RDR)

2. Plans, Strategies, and Programs (PSP)

3. Financing and Budgeting (FB)

4. Planning Studies and Reports (PSR)

5. County Services and Operations (SO)

6. Inter-governmental Coordination (IGC)

7. Joint Partnerships with the Private Sector (JP)a

8. Public Information (PI)
The following San Joaquin County General Plan Land Use (LU) Element goals and policies related to groundwater use will potentially influence implementation of the GSP.
• Policy LU-1.1 Compact Growth and Development (RDR): The County shall discourage urban sprawl and promote compact development patterns, mixed-use development, and higher-development intensities that conserve agricultural land resources, protect habitat, support transit, reduce vehicle trips, improve air quality, make efficient use of existing infrastructure, encourage healthful, active living, conserve energy and water, and diversify San Joaquin County's housing stock.
• Policy LU-1.7 Farmland Preservation (RDR): The County shall consider information from the State Farmland Mapping and Monitoring Program when designating future growth areas in order to preserve prime farmland and limit the premature conversion of agricultural lands. • Policy LU 2.2 Sustainable Building Practices (RDR): The County shall promote and, where appropriate, require sustainable building practices that incorporate a “whole system” approach to designing and constructing buildings that consume less energy, water and other resources, facilitate natural ventilation, use daylight effectively, and are healthy, safe, comfortable, and durable. • Policy LU-2.17 Delta Primary Zone Amendments (RDR/PSP): The County shall require proposed General Plan amendment or zoning reclassification for areas in the Primary Zone of the Delta to be consistent with the Land Use and Resource Management Plan for the Primary Zone of the Delta, as required by the State Delta Protection Act of 1992 (Public Resources Code 29700 et seq.). • Policy LU-8.1 Open Space Preservation (PSP): The County shall limit, to the extent feasible, the conversion of open space and agricultural lands to urban uses and place a high priority on preserving open space lands for recreation, habitat protection and enhancement, flood hazard management, public safety, water resource protection, and overall community benefit.

The following San Joaquin CountyGeneral Plan County Areas and Communities (C) Element goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Policy C-1.2 Character and Quality of Life (RDR): The County shall encourage new development in Urban and Rural communities to be designed to strengthen the desirable characteristics and historical character of the communities, be supported by necessary public facilities and services, and be compatible with historical resources and nearby rural or resource uses.

ATTACHMENT 2
• Policy C-5.2 Community Expansion Considerations (RDR/PSP): As part of any General Plan amendment to expand a community, the County shall consider the following:
o impacts on existing neighborhoods, residents, and businesses; o availability of a variety of housing choices for all socio-economic segments of the community; o the balance between jobs and housing;
o availability of water for all existing and planned development; o long-term provision of infrastructure and services for existing and planned development; o creation of complete streets that provide for automobiles, pedestrians, bicycles, and public transit users; o connections among pedestrian, bicycle, and open spaces and neighborhoods, commercial areas, and employment centers;
o impacts on the fiscal resources of the County and nearby cities. (RDR/PSP) • Policy C-6.18 New Urban Community Water Supply (RDR/PSP): The County shall require new Urban Communities demonstrate access to adequate water supplies to meet the ultimate buildout of the community, consistent with General Plan policies for reducing further groundwater aquifer overdraft and maintaining sufficient water supplies for agriculture. Applicants for new Urban Communities shall be required to study and guarantee, through a development agreement, that existing and future water supply needs can be met and that existing users’ water supplies will not be negatively impacted.

The following San Joaquin County General Plan Economic Development (ED) Element goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Policy ED-3.2 Considerations for New Commercial and Industrial Development (RDR): The County shall consider the following factors when reviewing proposed non-agricultural commercial and industrial development applications, including:
o Water – New developments must have long-term water supplies to meet the ultimate demand of the development and surrounding area and ensure the continued viability of existing and future development • Goal ED-4: To support the continued financial growth of the agricultural sector and ag-relatedbusinesses. • Policy ED-4.8 Protect Agricultural Infrastructure (PSP): The County shall recognize and protect agricultural infrastructure, such as farm-to-market routes, water diversion and conveyance structures, airfields, processing facilities, research and development facilities, and farmworker housing.

The following San Joaquin County General Plan Infrastructure and Services (IS) Element goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Goal IS-4: To ensure reliable supplies of water for unincorporated areas to meet the needs of existing and future residents and businesses, while promoting water conservation and the use of sustainable water supply sources.
• Policy IS-4.1 Interagency Cooperation (IGC): The County shall support efforts of local water agencies, special district, and water conservation districts to ensure that adequate high-quality water supplies are available to support existing and future residents and businesses.
• Policy IS-4.2 Interagency Cooperation (IGC): The County shall work with local water agencies to address existing and future water needs for the County.
• Policy IS-4.3 Water Supply Availability (RDR/PSP): The County shall consider the availability of a long-term, reliable potable water supply as a primary factor in the planning of areas for new growth and development. • Policy IS-4.4 Water Rights Protection (IGC): The County shall support local water agencies in their efforts to protect their water rights and water supply contracts, including working with Federal and State water projects to protect local water rights.

ATTACHMENT 2
• Policy IS-4.5 Drought Response (PSP/IGC): The County shall encourage all local water agencies to develop and maintain drought contingency and emergency services plans, emergency inter-ties, mutual aid agreements, and related measures to ensure adequate water service during drought or other emergency water shortages.
• Policy IS-4.6 Coordinate Efforts for Adequate Water Supply (PSP/IGC): The County shall support coordinated efforts to obtain adequate water supplies and develop water storage facilities tomeet expected water demand. • Policy IS-4.7 Conjunctive Use (PSP/IGC): The County shall support conjunctive use of groundwater and surface water by local water agencies to improve water supply reliability. • Policy IS-4.8 Water Conservation Measures (RDR): The County shall require existing and new development to incorporate all feasible water conservation measures to reduce the need for water system improvements. • Policy IS-4.9 Groundwater Management (IGC): The County shall continue to support cooperative, regional groundwater management planning by local water agencies, water users, and other affected parties to ensure a sustainable, adequate, safe, and economically viable groundwater supply for existing and future uses within the County.
• Policy IS-4.10 Groundwater Monitoring Program (PSR/IGC): The County shall continue to evaluate the quantity and quality of groundwater.
• Policy IS-4.11 Integrated Regional Water Management: The County shall support and participate in the development, implementation, and update of an integrated regional water management plan. • Policy IS-4.12 Water Supply Planning (PSP/IGC): The County shall encourage local water agencies to develop plans for responding to droughts and the effects of global climate change, including contingency plans, water resource sharing to improve overall water supply reliability, and the allocation of water supply to priority users.
• Policy IS-4.13 Water Quality Standards (RDR): The County shall require that water supplies serving new development meet State water quality standards. If necessary, the County shall require that water be treated to meet State standards and that a water quality monitoring program be in place prior to issuance of building permits.
• Policy IS-4.14 Sufficient Water Supply Assessments (RDR): The County shall require new developments over 500 dwelling units in size to prepare a detailed water source sufficiency study and water supply analysis for use in preparing a Water Supply Assessment, consistent with any Integrated Regional Water Management Plan or similar water management plan. This shall include analyzing the effect of new development on the water supply of existing users.
• Policy IS-4.15 Test Wells (RDR/PSR): Prior to issuing building permits for new development that will rely on groundwater, the County shall require confirmation for existing wells or test wells for new wells to ensure that water quality and quantity are adequate to meet the needs of existing, proposed, and planned future development.
• Policy IS-4.16 Permit for Groundwater Export (RDR): The County shall continue to require a permit for the extraction of groundwater that is intended to be exported outside County boundaries. • Policy IS-4.17 Advocate Against Water Exports (PSP): The County shall advocate that water should not be exported to other areas of the state unless no other areas in San Joaquin County are impacted and the current and future needs of San Joaquin County can still bemet. • Policy IS-4.19 Water Efficient Landscaping (RDR): The County shall encourage water efficient landscaping and use of native, drought-tolerant plants consistent with the Model LandscapeOrdinance.

ATTACHMENT 2
• Policy IS-4.20 Water Efficient Agricultural Practices (PSP): The County shall encourage farmers to implement irrigation practices, where feasible and practical, to conserve water. • Goal IS-5: To maintain an adequate level of service in the water systems serving unincorporated areas to meet the needs of existing and future residents and businesses, while improving water system efficiency. • Policy IS-5.1 Adequate Water Treatment and Distribution Facilities (RDR): The County shall ensure, through the development review process, that adequate water, treatment and distribution facilities are sufficient to serve new development and are scalable to meet capacity demands when needed. Such needs shall include capacities necessary to comply with water quality and public safety requirements. • Policy IS-5.2 Water System Standards (RDR): The County shall require the minimum standards for water system improvements provided in Table IS-1 for the approval of tentative maps and zone reclassifications. • Policy IS-5.3 Water Service in Antiquated Subdivisions (RDR): The County shall require water service through a public water system prior to issuance of building permits for new residences on parcels less than two acres in antiquated subdivisions. Individual wells may be allowed if public water is not available and all well and sewage requirements can be met.
• Policy IS-5.4 Water Infrastructure Fees (RDR): As a condition of approval for new developments, the County shall require verification of payment of fees imposed for water infrastructure capacity per the fee payment schedule from the appropriate local agency prior to the approval of any final subdivisionmap. • Policy IS-5.5 Water System Rehabilitation (PSP): The County shall encourage the rehabilitation of irrigation systems and other water delivery systems to reduce water losses and increase the efficient use and availability of water.
• Policy IS-5.6 Consistent Fire Protection Standards for New Development (RDR/IGC): The County, in coordination with local water agencies and fire protection agencies, shall ensure consistent and adequate standards for fire flows and fire protection for new development.

The following San Joaquin County General Plan Resource Conservation and Sustainability (NCR) goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Policy NCR-3.1 Preserve Groundwater Recharge Areas (PSP): The County shall strive to ensure that substantial groundwater recharge areas are maintained as open space. • Policy NCR-3.2 Groundwater Recharge Projects (PSP): The County shall encourage the development of groundwater recharge projects of all scales within the County and cities to increase groundwater supplies. • Policy NCR-3.3 Multi-Jurisdictional Groundwater Management Evaluation (IGC): The County shall support multi-jurisdictional groundwater management that involves adjacent groundwater basins. • Policy NCR-3.4 Eliminate Pollution (PSP): The County shall support efforts to eliminate sources of pollution and clean up the County's waterways and groundwater.
• Policy NCR-3.7 Septic Tank Regulation (RDR): The County shall enforce its septic tank and onsite system regulations consistent with Central Valley Regional Water Quality Control Board policy that recognizes the County as the responsible agency to protect the water quality of surface water and groundwater.

The following San Joaquin County General Plan Delta Element (D) goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Policy D-2.4 Water Rights (RDR/PSP): The County shall protect existing water rights within the Delta, including the “area of origin” laws and anti-degradation policy of the SWRCB for areas in the Delta, such that there is no deprivation of the water needed for present and future reasonable beneficial use in the areas where the water originates.

ATTACHMENT 2
• Goal D-4: To regulate development within the Delta to ensure the long-term viability of agricultural operations, success of natural ecosystems, and continuation of Delta heritage • Goal D-6: To protect Delta water supplies for agricultural uses and ecosystems enhancement and improve overall Delta water quality.
• Policy D-6.2 Protect Delta Water Rights: The County shall defend the existing water right priority system and legislative protections established for the Delta.
• Policy D-6.5 Water StorageOptions (IGC/PSR): The County shall advocate for the study of above- and belowground storage options as part of a statewide improved flood management and water supply system.

Calaveras County General Plan
The following Calaveras County General Plan Land Use Element goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Policy II-25B: Encourage the development of alternative individual waste disposal systems which minimize pollution and water usage.

The following Calaveras County General Plan Conservation Element goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Goal IV-1: Preserve and encourage the use of land for agriculture purposes. • Policy IV-1A: Allow resource production lands to remain available for agriculture and rural use. • Goal IV-2: Protect legally established agriculture from encroachment by incompatible land uses. • Goal IV-3: Preserve and encourage the expansion of high capability timber lands for timber protection and harvest.
• Policy IV-3A: Allow lands located within high capability timberlands to remain available for timber production. • Goal IV-4: Maintain and increase timber land productivity. • Policy IV-4A: Encourage sustained yield timber production and harvest. • Goal IV-9: Preserve the County's current water rights and additional water rights necessary to support the County's full development potential.
• Policy IV-9A: Support the development of water projects in the County for domestic and irrigation purposes. • Goal IV-10: Provide for adequate domestic water supplies. • Policy IV-10A: Encourage continued cooperation among water suppliers in meeting the water needs for the County as a whole.

The following Calaveras County General Plan Open Space Element goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Goal V-2: Protect streams, rivers, and lakes from excessive sedimentation due to development and grading. • Policy V-2A: Review proposed development projects for potential effects on nearby and adjacent streams, rivers, and lakes.
• Goal V-3: Protect and preserve riparian habitat along streams and rivers in the County.

ATTACHMENT 2
• Policy V-9A: Balance water resources development with the preservation of streams and rivers in their natural state.

Stanislaus County General Plan
The following Stanislaus County General Plan Land Use Element goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Goal 1: Provide for diverse land use needs by designating patterns which are responsive to the physical characteristics of the land as well as to environmental, economic, and social concerns of the residents of Stanislaus County.
• Policy 2: Land designated Agriculture shall be restricted to uses that are compatible with agricultural practices, including natural resources management, open space, outdoor recreation, and enjoyment of scenic beauty. • Policy 4: Urban development shall be discouraged in areas with growth-limiting factors such as high water table or poor soil percolation, and prohibited in geological fault and hazard areas, flood plains, riparian areas, and airport and private airstrip hazard areas, unless measures to mitigate the problems are included as part of the application.
• Policy 7: Riparian habitat along the rivers and natural waterways of Stanislaus County shall, to the extent possible, be protected.
• Policy 14: Uses shall not be permitted to intrude into or be located adjacent to an agricultural area if they are detrimental to continued agricultural usage of the surrounding area. • Policy 17: Agriculture, as the primary industry of the County, shall be promoted and protected. • Policy 24: Future growth shall not exceed the capabilities/capacity of the provider of services such as sewer, water, public safety, solid waste management, road systems, schools, health care facilities,etc. • Policy 29: Support the development of a built environment that is responsive to decreasing air and water pollution, reducing the consumption of natural resources and energy, increasing the reliability of local water supplies, and reduces vehicle miles traveled by facilitating alternative modes of transportation, and promoting active living (integration of physical activities, such as biking and walking, into everyday routines) opportunities.
• Goal 7: Provide for direct citizen participation in land use decisions involving the expansion of residential uses into agricultural and open-space areas in order to encourage compact urban form and to preserve agricultural land.

The following Stanislaus County General Plan Conservation/Open Space Element goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Goal 2: Conserve water resources and protect water quality in the County. • Policy 5: Protect groundwater aquifers and recharge areas, particularly those critical for the replenishment of reservoirs and aquifers.
• Policy 6: Preserve natural vegetation to protect waterways from bank erosion and siltation. • Policy 7: New development that does not derive domestic water from pre-existing domestic and public water supply systems shall be required to have a documented water supply that does not adversely impact Stanislaus County water resources.
• Policy 8: The County shall support efforts to develop and implement water management strategies • Policy 9: The County will investigate additional sources of water for domestic use.

ATTACHMENT 2
The following Stanislaus County General Plan Agricultural Element goals and policies related to groundwater use will potentially influence implementation of the GSP:
• Goal 1: Strengthen the agricultural sector of our economy. • Policy 1.1: Efforts to promote the location of new agriculture-related business and industry in Stanislaus County shall be supported.
• Policy 1.10: The County shall protect agricultural operations from conflicts with non-agricultural uses by requiring buffers between proposed non-agricultural uses and adjacent agricultural operations. • Goal 2: Conserve our agricultural lands for agricultural uses. • Goal 3: Protect the natural resources that sustain our agricultural industry. • Policy 3.4: The County shall encourage the conservation of water for both agricultural, rural domestic, and urban uses.
• Policy 3.5: The County will continue to protect the quality of water necessary for crop production and marketing.
• Policy 3.6: The County will continue to protect local groundwater for agricultural, rural domestic, and urban use in Stanislaus County.

City of Stockton General Plan
• Policy SAF-3.2: Protect the availability of clean potable water from groundwater sources. • Policy SAF-3.2A (PFS-2.11): Continue to cooperate with San Joaquin County, SEWD, and Cal Water to monitor groundwater withdrawals and ensure that they fall within the target yield for the drinking water aquifer. • Policy SAF-3.3: Encourage use of recycled ("gray") water for landscaping irrigation to reduce demand on potable supplies.
• Policy SAF-3.3A: Require new development to install non-potable water infrastructure for irrigation of large landscaped areas where feasible.
• Policy SAF-3.3B: Investigate and implement Code amendments to allow installation of dual plumbing and/or rainwater capture systems to enable use of recycled water and/or captured rainwater generatedon-site. • Policy SAF-3.4A: Require all new urban development to be served by an adequate wastewater collection system to avoid possible contamination of groundwater from onsite wastewater disposal systems.

City of Lodi General Plan
• Policy GM-G2: Provide infrastructure—including water, sewer, stormwater, and solid waste/recycling systems—that is designed and timed to be consistent with projected capacity requirements and development phasing.
• Policy GM-G3: Promote conservation of resources in order to reduce the load on existing and planned infrastructure capacity, and to preserve existing environmental resources. • Policy GM-P8: Ensure that public facilities and infrastructure—including water supply, sewer, and stormwater facilities—are designed to meet projected capacity requirements to avoid the need for future replacement and upsizing, pursuant to the General Plan and relevant master planning. • Policy GM-P12: Require water conservation in both City operations and private development to minimize the need for the development of new water sources and facilities. To the extent practicable, promote water conservation and reduced water demand by:

ATTACHMENT 2
• Requiring the installation of non-potable water (recycled or gray water) infrastructure for irrigation of landscaped areas over one acre of new landscape acreage, where feasible. Conditions of approval shall require connection and use of nonpotable water supplies when available at the site. • Encouraging water-conserving landscaping, including the use of drought-tolerant and native plants, xeriscaping, use of evapotranspiration water systems, and other conservation measures. • Encouraging retrofitting of existing development with water-efficient plumbing fixtures, such as ultra lowflow toilets, waterless urinals, low-flow sinks and showerheads, and water efficient dishwashers and washing machines.
• Policy C-P7 Agricultural Soil Resources: Adopt an agricultural conservation program (ACP) establishing a mitigation fee to protect and conserve agricultural lands. The ACP shall include the collection of an agricultural mitigation fee for acreage converted from agricultural to urban use, taking into consideration all fees collected for agricultural loss (i.e., AB1600). Themitigation fee collected shall fund agricultural conservation easements, fee title acquisition, and research; the funding of agricultural education and local marketing programs; other capital improvement projects that clearly benefit agriculture (e.g., groundwater recharge projects); and administrative fees through an appropriate entity (“Administrative Entity”) pursuant to an administrative agreement. Goal CO-2: Prevent the creation of new groundwater contamination or the spread of existing contamination.
• Policy C-P13 Biological Resources: Support the protection, restoration, expansion, and management of wetland and riparian plant communities along the Mokelumne River for passive recreation, groundwater recharge, and wildlife habitat.
• Policy C-P27 Hydrology and Water Quality: Monitor the water quality of the Mokelumne River and Lodi Lake, in coordination with San Joaquin County, to determine when the coliform bacterial standard for contact recreation and the maximum concentration levels of priority pollutants, established by the California Department of Health Services, are exceeded. Monitor the presence of pollutants and variables that could cause harm to fish, wildlife, and plant species in the Mokelumne River and Lodi Lake. Post signs at areas used by water recreationists warning users of health risks whenever the coliform bacteria standard for contact recreation is exceeded. Require new industrial development to not adversely affect water quality in the Mokelumne River or in the area’s groundwater basin. Control use of potential water contaminants through inventorying hazardous materials used in City and industrial operations. • Policy C-P34 Hydrology and Water Quality: Protect groundwater resources by working with the county to prevent septic systems in unincorporated portions of the county that are in the General Plan Land Use Diagram on parcels less than two acres.
• Policy GM-P17 Potable Water Supply: Cooperate with Northeastern San Joaquin County Groundwater Banking Authority, other member water agencies, and the WID to retain surface water rights and groundwater supply.

City of Manteca General Plan
• Policy PF-P-5 Public Facilities and Services Element: The City will continue to rely principally on groundwater resources for its municipal water in the near term and will participate in the regional improvements to deliver surface water to augment the City's groundwater supply. • Policy PF-P-15 Public Facilities and Services Element: The City shall monitor water quality regularly and take necessary measures to prevent contamination.
• Policy PF-P-16 Public Facilities and Services Element: The City shall include a groundwater analysis as a technical analysis of water system capacity in the update of the Public Facilities Implementation Plan (PFIP) and shall prepare an environmental analysis in the PFIP that addresses the quality and availability of groundwater.
• Policy PF-P-17 Public Facilities and Services Element: The City shall consider incremental increases in the demands on groundwater supply and water quality when reviewing development applications.

ATTACHMENT 2
• Policy RC-P-3 Resource Conservation Element – Water Conservation: The City shall protect the quantity of Manteca’s groundwater.
• Policy RC-P-4 Resource Conservation Element – Water Conservation: The City shall require water conservation in both City operations and private development to minimize the need for the development of new water sources.
• Policy RC-P-5 Resource Conservation Element – Water Conservation: Development of private water wells within the city limits shall be allowed only where the City makes a finding that municipal water service is not readily and feasibly available, and such private well systems shall only be allowed to be used until such time as City water service becomes available.
• Policy RC-1.10: Where feasible, encourage and support multipurpose detention basins that provide water quality protection, storm water detention, groundwater recharge, open space amenities, and recreational amenities.
• Goal RC02: Groundwater: Manage and enhance groundwater as a valuable and limited shared resource on a sustainable yield basis that can provide water purveyors and individual users with reliable, high quality groundwater to serve existing and planned land uses during prolonged drought periods. • Policy RC-P-14 Resource Conservation Element – Water Conservation: Encourage participation by the County and surrounding communities in a basin-wide groundwater management study. • Policy S-P-1 Safety Element: The City shall require preparation of geological reports and/or geological engineering reports for proposed new development located in areas of potentially significant geological hazards, including potential subsidence (collapsible surface soils) due to groundwater extraction.

City of Escalon General Plan
• Policy 2.4 (2) Public Safety Standard: It is the policy of the City to require that water supply systems be related to the size and configuration of land developments. Standards as set forth in the current subdivision ordinance shall be maintained and improved as necessary.
• Objective 3.1 (A) Natural Resources: Protect natural resources including groundwater, soils, and air quality to meet the needs of present and future generations.
• Policy 3.1 (1) Natural Resources: Expand programs that enhance groundwater recharge in order to maintain the groundwater supply, including the installation of retention ponds in new growth areas. • Policy 3.1 (3) Natural Resources: Policy 3.1 (1) Natural Resources: Expand programs that enhance groundwater recharge in order to maintain the groundwater supply, including the installation of retention ponds in new growth areas.
• Policy 7.1 (1) Public and Institutional Land Use: Update the water, wastewater and storm drainage master plans, and any other specific or master plans related to infrastructure development on a periodic basis. • Policy 9.1 (12) Public Facility Improvement: To encourage groundwater recharge, ponding basins shall be designed as retention basins. However, pumping facilities shall be included in such facilities to handle peak flows and to provide for disposal of stormwater into irrigation ditches when necessary. Stormwater inflow into irrigation district canals and pipelines shall be subject to existing or future agreements by and between the City and the irrigation districts specifying maximum inflow, maximum service area boundary, and any other limitation thereto.
• Policy 9.1 (14) Public Facility Improvement: New municipal water well sites should be planned which include pump, storage, pressure filtration, and/or treatment equipment. These new wells should be located so that they will not conflict with planned residential neighborhoods. They should have design, screening, landscaping, and architectural improvements which make them compatible with adjacent landuses.

ATTACHMENT 2
City of Ripon General Plan
• Goal D: To reduce the impact of urban development on surrounding agricultural and riparian habitat as much as possible, consistent with the policies of the general plan. • Policy D5: The City shall implement the Groundwater Management Plan adopted by the City Council. This program includes but is not necessarily limited to: the ongoing collection and analysis of well quantity and quality data; the identification of recharge areas within the Planning Area; inter-agency coordination and planning to protect and enhance recharge areas; establishment of a well head protection program to ensure well and aquifer testing for new city wells; and the installation of monitoring wells, as required. • Policy D6. The City shall review design and operation parameters for storm water detention facilities and make feasible adjustments to these plans, which would promote recharge of storm water to the groundwater system. For example, siting detention facilities in areas of maximum infiltration capacity; increasing detention time for where necessary storage capacity is not compromised, and adjustment of area/depth ratios to maximize infiltration.
• Goal F: Groundwater management pursuant to the City’s Urban Water Management Plans to avoid overdraft and maintain drinking water quality.
• Policy F1. Expand City’s existing system to regularly monitor and evaluate the physical condition and quality of the groundwater system underlying Ripon, and to identify the need for supplemental water as required. • Policy F2. Identify and secure available sources of supplemental surface water for replacement or recharge of groundwater as required.
• Policy F3. Manage land use and sewage disposal as required to maintain adequate groundwaterquality. • Goal G: Efficient use of water resources throughout the community pursuant to the City’s Groundwater Management and Preservation Plan.
• Policy G1. Promote water conservation through public dissemination of groundwater and municipal water use information.
• Policy G2. Develop a plan, financing mechanism, and target date for installation of water meters on unmetered portions of the water system. • Policy G3. Promote reclamation and reuse of municipal and industrial wastewaters for irrigation, recharge, or other beneficial uses.
• Policy D5. The City shall implement the Groundwater Management Plan adopted by the City Council. This program includes, but is not necessarily limited to: the ongoing collection and analysis of well quantity and quality data; the identification of recharge areas within the Planning Area; inter-agency coordination and planning to protect and enhance recharge areas; establishment of a well head protection program to ensure well and aquifer testing for new city wells; and the installation of monitoring wells, as required. • Policy D6. The City shall review design and operation parameters for stormwater detention facilities and make feasible adjustments to these plans, which would promote recharge of stormwater to the groundwater system.

For example, siting detention facilities in areas of maximum infiltration capacity, increasing detention time for where necessary storage capacity is not compromised, and adjustment of area/depth ratios to maximize infiltration.

ATTACHMENT 2
This page is intentionally left blank.

ATTACHMENT 2
2024
Groundwater Sustainability Plan Amendment
Complete Appendices November 2024
APPENDIX 1-G.

FRESHWATER SPECIES IN ESJ SUBBASIN
ATTACHMENT 2
Freshwater Species in the Eastern San Joaquin Subbasin
Source: The following information was compiled by The Nature Conservancy and included with comments submitted May 31, 2019.

Methodology: ArcGIS was used to select features within the California Freshwater Species Database version 2.0.9 within the GSA’s boundary. This database contains information on ~4,000 vertebrates, macroinvertebrates and vascular plants that depend on fresh water for at least one stage of their life cycle. The methods used to compile the California Freshwater Species Database can be found in Howard et al. 20151. The spatial database contains locality observations and/or distribution information from ~400 data sources. The database is housed in the California Department of Fish and Wildlife’s BIOS2 as well as on The Nature Conservancy’s science website3.” Scientific Name Common Name
Legal Protected Status
Federal State Other
BIRDS
Actitis macularius Spotted Sandpiper
Aechmophorus clarkii Clark's Grebe
Aechmophorus occidentalis Western Grebe
Agelaius tricolor Tricolored Blackbird
Bird of
Conservation
Concern
Special Concern BSSC - First
priority
Aix sponsa Wood Duck
Anas acuta Northern Pintail
Anas americana American Wigeon
Anas clypeata Northern Shoveler
Anas crecca Green-winged Teal
Anas cyanoptera Cinnamon Teal
Anas discors Blue-winged Teal
Anas platyrhynchos Mallard
Anas strepera Gadwall
Anser albifrons Greater White-fronted
Goose
Ardea alba Great Egret
Ardea herodias Great Blue Heron
1 Howard, J.K. et al. 2015. Patterns of Freshwater Species Richness, Endemism, and Vulnerability in California. PLoSONE, 11(7). Available at: https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0130710 2 California Department of Fish and Wildlife BIOS: https://www.wildlife.ca.gov/data/BIOS 3 Science for Conservation: https://www.scienceforconservation.org/products/california-freshwater-species- database ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Aythya affinis Lesser Scaup
Aythya americana Redhead Special Concern BSSC - Third
priority
Aythya collaris Ring-necked Duck
Aythya marila Greater Scaup
Aythya valisineria Canvasback Special
Botaurus lentiginosus American Bittern
Bucephala albeola Bufflehead
Bucephala clangula Common Goldeneye
Butorides virescens Green Heron
Calidris alpina Dunlin
Calidris mauri Western Sandpiper
Calidris minutilla Least Sandpiper
Chen caerulescens Snow Goose
Chen rossii Ross's Goose
Chlidonias niger Black Tern Special Concern BSSC - Second priority
Chroicocephalus philadelphia Bonaparte's Gull
Cinclus mexicanus American Dipper
Cistothorus palustris
palustris Marsh Wren
Cygnus buccinator Trumpeter Swan
Cygnus columbianus Tundra Swan
Cypseloides niger Black Swift
Bird of
Conservation
Concern
Special Concern BSSC - Third
priority
Egretta thula Snowy Egret
Empidonax traillii Willow Flycatcher
Bird of
Conservation
Concern Endangered
Fulica americana American Coot
Gallinago delicata Wilson's Snipe
Gallinula chloropus Common Moorhen
Geothlypis trichas trichas Common Yellowthroat
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Grus canadensis Sandhill Crane
Grus canadensis
canadensis Lesser Sandhill Crane Special Concern BSSC - Third priority Haliaeetus leucocephalus Bald Eagle
Bird of
Conservation
Concern Endangered
Himantopus mexicanus Black-necked Stilt
Icteria virens Yellow-breasted Chat Special Concern BSSC - Third priority
Laterallus jamaicensis
coturniculus California Black Rail
Bird of
Conservation
Concern Threatened
Limnodromus scolopaceus Long-billed Dowitcher
Lophodytes cucullatus Hooded Merganser
Megaceryle alcyon Belted Kingfisher
Mergus merganser Common Merganser
Mergus serrator Red-breasted Merganser
Numenius americanus Long-billed Curlew
Numenius phaeopus Whimbrel
Nycticorax nycticorax Black-crowned NightHeron
Oreothlypis luciae Lucy's Warbler Special Concern BSSC - Third priority
Oxyura jamaicensis Ruddy Duck
Pelecanus erythrorhynchos American White Pelican Special Concern BSSC - First priority
Phalacrocorax auritus Double-crested Cormorant
Phalaropus tricolor Wilson's Phalarope
Piranga rubra Summer Tanager Special Concern BSSC - First priority
Plegadis chihi White-faced Ibis Watch list
Pluvialis squatarola Black-bellied Plover
Podiceps nigricollis Eared Grebe
Podilymbus podiceps Pied-billed Grebe
Porzana carolina Sora
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Rallus limicola Virginia Rail
Recurvirostra americana American Avocet
Riparia riparia Bank Swallow Threatened
Setophaga petechia Yellow Warbler BSSC - Second
priority
Tachycineta bicolor Tree Swallow
Tringa melanoleuca Greater Yellowlegs
Tringa semipalmata Willet
Tringa solitaria Solitary Sandpiper
Vireo bellii pusillus Least Bell's Vireo Endangered Endangered Xanthocephalus
xanthocephalus Yellow-headed Blackbird Special Concern BSSC - Third priority

CRUSTACEANS
Branchinecta lynchi Vernal Pool Fairy Shrimp Threatened Special IUCN - Vulnerable
Branchinecta mesovallensis Midvalley Fairy Shrimp Special Cambaridae fam. Cambaridae fam.

Crangonyx spp. Crangonyx spp.

Gnorimosphaeroma insulare An Isopod
Hyalella spp. Hyalella spp.

Lepidurus packardi Vernal Pool Tadpole
Shrimp Endangered Special IUCN -Endangered
Linderiella occidentalis California Fairy Shrimp Special IUCN - Near Threatened
FISH
Acipenser medirostris ssp.
1 Southern green sturgeon Threatened Special Concern Endangered - Moyle 2013
Mylopharodon conocephalus Hardhead Special Concern
NearThreatened -
Moyle 2013
Oncorhynchus mykiss - CV Central Valley steelhead Threatened Special Vulnerable - Moyle 2013
Oncorhynchus mykiss
irideus Coastal rainbow trout Least Concern -Moyle 2013 ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Pogonichthys macrolepidotus Sacramento splittail Special Concern Vulnerable - Moyle 2013
Spirinchus thaleichthys Longfin smelt Candidate Threatened Vulnerable - Moyle 2013
Acipenser medirostris ssp.
1 Southern green sturgeon Threatened Special Concern Endangered - Moyle 2013
Acipenser transmontanus White sturgeon Special Vulnerable - Moyle 2013
Catostomus occidentalis
occidentalis Sacramento sucker Least Concern -Moyle 2013 Cottus asper ssp. 1 Prickly sculpin Least Concern -
Moyle 2013
Cottus gulosus Riffle sculpin Special
NearThreatened -
Moyle 2013
Entosphenus tridentata ssp.
1 Pacific lamprey Special
NearThreatened -
Moyle 2013
Gasterosteus aculeatus
microcephalus
Inland threespine
stickleback Special Least Concern -Moyle 2013
Hypomesus pacificus Delta smelt Threatened Endangered Endangered - Moyle 2013
Hysterocarpus traskii traskii Sacramento tule perch Special NearThreatened -
Moyle 2013
Lampetra ayersi River lamprey Special Concern
NearThreatened -
Moyle 2013
Lampetra richardsoni Western brook lamprey
NearThreatened -
Moyle 2013
Lavinia exilicauda exilicauda Sacramento hitch Special
NearThreatened -
Moyle 2013
Lavinia symmetricus
symmetricus Central California roach
Special Concern NearThreatened -
Moyle 2013
Mylopharodon conocephalus
Hardhead
Special Concern NearThreatened -
Moyle 2013
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Oncorhynchus gorbuscha Pink salmon Special Concern Endangered - Moyle 2013
Oncorhynchus mykiss - CV Central Valley steelhead Threatened Special Vulnerable - Moyle 2013
Oncorhynchus mykiss
irideus
Coastal rainbow trout Least Concern -
Moyle 2013
Oncorhynchus tshawytscha
- CV fall
Central Valley fall Chinook
salmon
Species of
Special Concern
Special Concern Vulnerable -
Moyle 2013
Oncorhynchus tshawytscha
- CV late fall
Central Valley late fall
Chinook salmon
Species of
Special Concern
Endangered -
Moyle 2013
Oncorhynchus tshawytscha
- CV spring
Central Valley spring
Chinook salmon
Threatened Threatened Vulnerable -
Moyle 2013
Orthodon microlepidotus Sacramento blackfish Least Concern - Moyle 2013
Pogonichthys macrolepidotus Sacramento splittail Special Concern Vulnerable - Moyle 2013
Ptychocheilus grandis Sacramento pikeminnow Least Concern - Moyle 2013
Rhinichthys osculus ssp. 1 Sacramento speckled dace Least Concern - Moyle 2013
Spirinchus thaleichthys Longfin smelt Candidate Threatened Vulnerable - Moyle 2013
HERPS
Actinemys marmorata
marmorata
Western Pond Turtle Special Concern ARSSC
Ambystoma californiense
californiense
California Tiger Salamander Threatened Threatened ARSSC Anaxyrus boreas boreas Boreal Toad
Anaxyrus boreas halophilus California Toad ARSSC
Rana boylii Foothill Yellow-legged Frog
Under Review in
the Candidate or
Petition
Process
Special Concern ARSSC
Rana draytonii California Red-legged Frog Threatened Special Concern ARSSC Spea hammondii Western Spadefoot
Under Review in
the Candidate or
Petition
Process
Special Concern ARSSC
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Taricha torosa Coast Range Newt Special Concern ARSSC
Thamnophis couchii Sierra Gartersnake
Thamnophis elegans
elegans
Mountain Gartersnake Not on any
status lists
Thamnophis elegans
terrestris
Coast Gartersnake Not on any
status lists
Thamnophis gigas Giant Gartersnake Threatened Threatened Thamnophis sirtalis fitchi Valley Gartersnake Not on any status lists
Thamnophis sirtalis sirtalis Common Gartersnake

INSECTS & OTHER INVERTEBRATES
Ablabesmyia annulata Not on any
status lists
Ablabesmyia spp. Ablabesmyia spp.

Aeshna spp. Aeshna spp.

Anax junius Common Green Darner
Apedilum spp. Apedilum spp.

Caenis latipennis A Mayfly
Centroptilum album A Mayfly
Centroptilum spp. Centroptilum spp.

Chironomidae fam. Chironomidae fam.

Chironomus spp. Chironomus spp.

Cladopelma spp. Cladopelma spp.

Cladotanytarsus spp. Cladotanytarsus spp.

Coenagrionidae fam. Coenagrionidae fam.

Corisella spp. Corisella spp.

Corixidae fam. Corixidae fam.

Cricotopus annulator Not on any
status lists
Cricotopus spp. Cricotopus spp.

Cryptochironomus curryi Not on any
status lists
Cryptochironomus spp. Cryptochironomus spp.

Cryptotendipes spp. Cryptotendipes spp.

ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Dicrotendipes spp. Dicrotendipes spp.

Enallagma carunculatum Tule Bluet
Enallagma civile Familiar Bluet
Endotribelos spp. Endotribelos spp.

Fallceon quilleri A Mayfly
Fallceon spp. Fallceon spp.

Glyptotendipes spp. Glyptotendipes spp.

Gomphus spp. Gomphus spp.

Hydrophilidae fam. Hydrophilidae fam.

Hydropsyche spp. Hydropsyche spp.

Hydropsychidae fam. Hydropsychidae fam.

Hydroptila spp. Hydroptila spp.

Hydroptilidae fam. Hydroptilidae fam.

Ischnura cervula Pacific Forktail
Ischnura spp. Ischnura spp.

Liodessus obscurellus Not on any
status lists
Micrasema arizonica Not on any
status lists
Micrasema spp. Micrasema spp.

Microchironomus
nigrovittatus
Not on any
status lists
Microchironomus spp. Microchironomus spp.

Micropsectra spp. Micropsectra spp.

Mideopsis spp. Mideopsis spp.

Nanocladius spp. Nanocladius spp.

Nectopsyche spp. Nectopsyche spp.

Oxyethira aculea Not on any
status lists
Oxyethira spp. Oxyethira spp.

Pachydiplax longipennis Blue Dasher
Pantala flavescens Wandering Glider
Pantala hymenaea Spot-winged Glider
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Paracladopelma alphaeus Not on any
status lists
Paracladopelma spp. Paracladopelma spp.

Parakiefferiella spp. Parakiefferiella spp.

Paratanytarsus grimmii Not on any
status lists
Paratanytarsus spp. Paratanytarsus spp.

Peltodytes callosus Not on any
status lists
Peltodytes spp. Peltodytes spp.

Pentaneura spp. Pentaneura spp.

Phaenopsectra spp. Phaenopsectra spp.

Plathemis lydia Common Whitetail
Polypedilum albicorne Not on any
status lists
Polypedilum spp. Polypedilum spp.

Procladius spp. Procladius spp.

Psectrocladius spp. Psectrocladius spp.

Pseudosmittia spp. Pseudosmittia spp.

Rheotanytarsus spp. Rheotanytarsus spp.

Rhionaeschna multicolor Blue-eyed Darner
Robackia demeijeri Not on any
status lists
Sigara alternata Not on any
status lists
Sigara mckinstryi A Water Boatman Not on any
status lists
Sigara spp. Sigara spp.

Simulium anduzei Not on any
status lists
Simulium spp. Simulium spp.

Sperchon spp. Sperchon spp.

Sympetrum corruptum Variegated Meadowhawk
Tanypus spp. Tanypus spp.

ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Tanytarsus angulatus Not on any
status lists
Tanytarsus spp. Tanytarsus spp.

Tramea lacerata Black Saddlebags
Trichocorixa calva Not on any
status lists
Tricorythodes spp. Tricorythodes spp.

MAMMALS
Castor canadensis American Beaver Not on any
status lists
Lontra canadensis
canadensis
North American River Otter Not on any
status lists
Neovison vison American Mink Not on any
status lists
Ondatra zibethicus Common Muskrat Not on any
status lists

MOLLUSKS
Anodonta californiensis California Floater Special
Ferrissia spp. Ferrissia spp.

Galba spp. Galba spp.

Gonidea angulata Western Ridged Mussel Special
Gyraulus spp. Gyraulus spp.

Helisoma spp. Helisoma spp.

Lymnaea spp. Lymnaea spp.

Margaritifera falcata Western Pearlshell Special
Menetus opercularis Button Sprite CS
Menetus spp. Menetus spp.

Physa acuta Pewter Physa Not on any
status lists
Physa spp. Physa spp.

Pisidium spp. Pisidium spp.

Planorbidae fam. Planorbidae fam.

Sphaeriidae fam. Sphaeriidae fam.

Sphaerium occidentale Not on any
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
status lists
Sphaerium spp. Sphaerium spp.

PLANTS
Alnus rhombifolia White Alder
Alopecurus saccatus Pacific Foxtail
Ammannia coccinea Scarlet Ammannia
Ammannia robusta Grand Redstem
Anemopsis californica Yerba Mansa
Arundo donax NA
Azolla filiculoides NA
Baccharis salicina Not on any
status lists
Bacopa eisenii Gila River Water-hyssop
Bergia texana Texas Bergia
Bidens laevis Smooth Bur-marigold
Bidens tripartita NA
Blennosperma bakeri Baker's Blennosperma Endangered Endangered CRPR - 1B.1 Boehmeria cylindrica NA Not on any
status lists
Brodiaea nana Not on any
status lists
Brodiaea pallida Chinese Camp Brodiaea Threatened Endangered CRPR - 1B.1 Callitriche heterophylla
bolanderi
Large Water-starwort
Callitriche heterophylla
heterophylla
Northern Water-starwort
Callitriche longipedunculata Longstock Water-starwort
Callitriche marginata Winged Water-starwort
Carex comosa Bristly Sedge Special CRPR - 2B.1
Carex densa Dense Sedge
Carex feta Green-sheath Sedge
Carex lenticularis Shore Sedge
Carex nudata Torrent Sedge
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Carex senta Western Rough Sedge
Castilleja campestris
succulenta
Fleshy Owl's-clover Threatened Endangered CRPR - 1B.2
Cephalanthus occidentalis Common Buttonbush
Ceratophyllum demersum Common Hornwort
Cicendia quadrangularis Oregon Microcala
Cirsium crassicaule Slough Thistle Special CRPR - 1B.1
Cotula coronopifolia NA
Crassula aquatica Water Pygmyweed
Crypsis vaginiflora NA
Cyperus acuminatus Short-point Flatsedge
Cyperus erythrorhizos Red-root Flatsedge
Cyperus fuscus NA
Cyperus squarrosus Awned Cyperus
Damasonium californicum Not on any
status lists
Datisca glomerata Durango Root
Downingia bella Hoover's Downingia
Downingia bicornuta NA
Downingia cuspidata Toothed Calicoflower
Downingia elegans NA
Downingia insignis Parti-color Downingia
Downingia ornatissima NA
Downingia pulchella Flat-face Downingia
Downingia pusilla Dwarf Downingia Special CRPR - 2B.2
Elatine brachysperma Shortseed Waterwort
Elatine californica California Waterwort
Elatine rubella Southwestern Waterwort
Eleocharis acicularis
acicularis
Least Spikerush
Eleocharis bella Delicate Spikerush
Eleocharis bolanderi Bolander's Spikerush
Eleocharis engelmannii Engelmann's Spikerush Not on any ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
engelmannii status lists
Eleocharis flavescens
flavescens
Pale Spikerush
Eleocharis macrostachya Creeping Spikerush
Eleocharis obtusa Blunt Spikerush
Eleocharis parishii Parish's Spikerush
Elodea canadensis Broad Waterweed
Epilobium campestre NA Not on any
status lists
Epilobium cleistogamum Cleistogamous Spikeprimrose
Eragrostis hypnoides Teal Lovegrass
Eryngium aristulatum
aristulatum
California Eryngo
Eryngium castrense Great Valley Eryngo
Eryngium pinnatisectum Tuolumne Coyote-thistle Special CRPR - 1B.2 Eryngium racemosum Delta Coyote-thistle Endangered CRPR - 1B.1 Eryngium vaseyi vallicola Not on any
status lists
Eryngium vaseyi vaseyi Vasey's Coyote-thistle Not on any status lists
Euphorbia hooveri NA Not on any
status lists
Euthamia occidentalis Western Fragrant
Goldenrod
Galium trifidum Small Bedstraw
Gratiola ebracteate Bractless Hedge-hyssop
Gratiola heterosepala Boggs Lake Hedge-hyssop Endangered CRPR - 1B.2 Gratiola neglecta Clammy Hedge-hyssop
Helenium bigelovii Bigelow's Sneezeweed
Helenium puberulum Rosilla
Hibiscus lasiocarpos
occidentalis
Special CRPR - 1B.2
Hippuris vulgaris Common Mare's-tail
Hosackia oblongifolia NA 1.B.3
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Hydrocotyle ranunculoides Floating Marsh-pennywort
Hydrocotyle verticillata
verticillata
Whorled Marsh-pennywort
Isoetes nuttallii NA
Isoetes orcuttii NA
Isolepis cernua Low Bulrush
Juncus acuminatus Sharp-fruit Rush
Juncus effusus effusus NA
Juncus effusus pacificus
Juncus phaeocephalus
paniculatus
Brownhead Rush
Juncus uncialis Inch-high Rush
Lasthenia ferrisiae Ferris' Goldfields Special CRPR - 4.2 Lasthenia fremontii Fremont's Goldfields
Leersia oryzoides Rice Cutgrass
Legenere limosa False Venus'-looking-glass Special CRPR - 1B.1 Lemna gibba Inflated Duckweed
Lemna minor Lesser Duckweed
Lemna minuta Least Duckweed
Lemna turionifera Turion Duckweed
Lepidium oxycarpum Sharp-pod Pepper-grass
Lilaeopsis masonii Mason's Lilaeopsis Special CRPR - 1B.1 Limnanthes alba alba White Meadowfoam
Limnanthes alba versicolor White Meadowfoam
Limnanthes douglasii
douglasii
Douglas' Meadowfoam
Limnanthes douglasii rosea Douglas' Meadowfoam
Limosella acaulis Southern Mudwort
Limosella aquatica Northern Mudwort
Limosella australis NA Special CRPR - 2B.1
Lindernia dubia Yellowseed False
Pimpernel
Lipocarpha micrantha Dwarf Bulrush
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Ludwigia grandiflora NA
Ludwigia peploides
montevidensis
NA Not on any
status lists
Ludwigia peploides
peploides
NA Not on any
status lists
Lycopus americanus American Bugleweed
Lythrum californicum California Loosestrife
Lythrum portula NA
Marsilea vestita vestita NA Not on any
status lists
Mimulus cardinalis Scarlet Monkeyflower
Mimulus guttatus Common Large
Monkeyflower
Mimulus latidens Broad-tooth Monkeyflower
Mimulus tricolor Tricolor Monkeyflower
Myosurus minimus NA
Myosurus sessilis Sessile Mousetail
Myriophyllum aquaticum NA
Najas guadalupensis
guadalupensis
Southern Naiad
Navarretia intertexta Needleleaf Navarretia
Navarretia leucocephala
leucocephala
White-flower Navarretia
Navarretia leucocephala
minima
Least Navarretia
Navarretia myersii myersii Pincushion Navarretia Special CRPR - 1B.1 Neostapfia colusana Colusa Grass Threatened Endangered CRPR - 1B.1 Oenanthe sarmentosa Water-parsley
Orcuttia inaequalis San Joaquin Valley Orcutt
Grass
Threatened Endangered CRPR - 1B.1
Orcuttia pilosa Hairy Orcutt Grass Endangered Endangered CRPR - 1B.1 Orcuttia tenuis Slender Orcutt Grass Threatened Endangered CRPR - 1B.1 Orcuttia viscida Sacramento Orcutt Grass Endangered Endangered CRPR - 1B.1 Panicum acuminatum
acuminatum
Not on any
status lists
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Panicum dichotomiflorum NA
Paspalum distichum Joint Paspalum
Perideridia bacigalupii Bacigalupi's Perideridia Special CRPR - 4.2 Perideridia bolanderi
bolanderi
Bolander's Yampah
Perideridia bolanderi
involucrata
Bolander's Yampah
Perideridia kelloggii Kellogg's Yampah
Perideridia lemmonii Lemmon's Yampah
Persicaria amphibia Not on any
status lists
Persicaria hydropiper NA Not on any
status lists
Persicaria hydropiperoides Not on any
status lists
Persicaria lapathifolia Not on any
status lists
Persicaria maculosa NA Not on any
status lists
Persicaria pensylvanica NA Not on any
status lists
Persicaria punctata NA Not on any
status lists
Phacelia distans NA
Phyla lanceolata Fog-fruit
Phyla nodiflora Common Frog-fruit
Pilularia americana NA
Plagiobothrys
acanthocarpus
Adobe Popcorn-flower
Plagiobothrys austiniae Austin's Popcorn-flower
Plagiobothrys distantiflorus California Popcorn-flower
Plagiobothrys greenei Greene's Popcorn-flower
Plagiobothrys humistratus Dwarf Popcorn-flower
Plagiobothrys leptocladus Alkali Popcorn-flower
Plagiobothrys reticulatus Not on any
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
reticulatus status lists
Plagiobothrys undulatus NA Not on any
status lists
Plantago elongata elongata Slender Plantain
Platanus racemosa California Sycamore
Pleuropogon californicus
californicus
Not on any
status lists
Pluchea odorata odorata Scented Conyza
Pogogyne douglasii NA
Pogogyne zizyphoroides Not on any
status lists
Potamogeton diversifolius Water-thread Pondweed
Potamogeton foliosus
foliosus
Leafy Pondweed
Potamogeton illinoensis Illinois Pondweed
Potamogeton nodosus Longleaf Pondweed
Primula subalpina Not on any
status lists
Psilocarphus brevissimus
brevissimus
Dwarf Woolly-heads
Psilocarphus brevissimus
multiflorus
Delta Woolly Marbles Special CRPR - 4.2
Psilocarphus oregonus Oregon Woolly-heads
Psilocarphus tenellus NA
Ranunculus aquatilis
aquatilis
White Water Buttercup
Ranunculus bonariensis NA
Ranunculus hystriculus Not on any
status lists
Ranunculus lobbii Lobb's Water Buttercup Special CRPR - 4.2 Ranunculus pusillus pusillus Pursh's Buttercup
Rorippa curvisiliqua
curvisiliqua
Curve-pod Yellowcress
Rorippa palustris palustris Bog Yellowcress
Rotala ramosior Toothcup
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Rumex conglomeratus NA
Rumex occidentalis Not on any
status lists
Rumex salicifolius
salicifolius
Willow Dock
Sagittaria latifolia latifolia Broadleaf Arrowhead
Sagittaria montevidensis
calycina
Not on any
status lists
Sagittaria sanfordii Sanford's Arrowhead Special CRPR - 1B.2 Salix exigua exigua Narrowleaf Willow
Salix exigua hindsiana Not on any
status lists
Salix gooddingii Goodding's Willow
Salix laevigata Polished Willow
Salix lasiolepis lasiolepis Arroyo Willow
Salix melanopsis Dusky Willow
Schoenoplectus acutus
occidentalis
Hardstem Bulrush
Schoenoplectus
californicus
California Bulrush
Scirpus microcarpus Small-fruit Bulrush
Sidalcea calycosa calycosa Annual Checker-mallow
Sidalcea hirsuta Hairy Checker-mallow
Sium suave Hemlock Water-parsnip
Spirodela polyrhiza NA
Stachys ajugoides Bugle Hedge-nettle
Stachys albens White-stem Hedge-nettle
Stachys pycnantha Short-spike Hedge-nettle
Stachys stricta Sonoma Hedge-nettle
Symphyotrichum lentum Suisun Marsh Aster Special CRPR - 1B.2 Taxus brevifolia
Toxicoscordion venenosum
venenosum
Not on any
status lists
ATTACHMENT 2
Scientific Name Common Name
Legal Protected Status
Federal State Other
Tuctoria greenei Green's Awnless Orcutt
Grass
Endangered Rare CRPR - 1B.1
Typha domingensis Southern Cattail
Typha latifolia Broadleaf Cattail
Utricularia gibba Humped Bladderwort
Veronica americana American Speedwell
Veronica anagallis-aquatica NA
Wolffia globosa Asian Watermeal
Wolffiella lingulata Tongue Bogmat
ATTACHMENT 2
APPENDIX 1-H.
2024 EASTERN SAN JOAQUIN SUBBASIN COMMUNICATION

AND ENGAGEMENT PLAN UPDATE
Groundwater Sustainability Plan
Complete Appendices November 2024
ATTACHMENT 2
ATTACHMENT 2
2024
Groundwater Sustainability Plan Amendment
Complete Appendices November 2024
APPENDIX 1-I.

PUBLIC COMMENTS RECEIVED
ATTACHMENT 2
1 From: [email protected] [PW] <[email protected]> Sent: Thursday, October 31, 2024 2:38 PM
To: Brandon Nakagawa <[email protected]>; Katie Cole <[email protected]> Subject: FW: Comments on ESJ Public Draft of the ESJ 2024 Groundwater Sustainability Plan Amendment From: Brent Barton <[email protected]>
Sent: Thursday, October 3, 2024 11:24 AM
To: [email protected] [PW] <[email protected]> Subject: Comments on ESJ Public Draft of the ESJ 2024 Groundwater Sustainability Plan Amendment Thank you for all the hard work you’ve put into the GSP to this point.

Most of our properties are in the San Joaquin County GSA, some is in the CSJWCD GSA… My comments are:

Let’s get to sustainability by increasing our water supply (i.e., bring additional surface water into the GWA areas). Let’s not allow ourselves to be forced into sustainability via mandated groundwater pumping restrictions. That would be disastrous.

We need to get the San Joaquin County GAS and the Central San Joaquin Water Conservation District GSA to be more proactive by submitting plans for increasing water supply.

Let us know if we can help.

Thank you again,
Brent Barton
Barton Ranch, Inc.

Escalon, CA
209-838-8930 farm office
209-404-0394 cell
You don't often get email from [email protected]. Learn why this is important ATTACHMENT 2
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director North Central Region
1701 Nimbus Road
Rancho Cordova, CA 95670
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
October 30, 2024
Fritz Buchman
Eastern San Joaquin Subbasin Plan Manager
San Joaquin County Public Works Department
1810 E. Hazelton Ave
Stockton, CA 95205
[email protected]
Subject: CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS ON THE

EASTERN SAN JOAQUIN BASIN AMENDED GROUNDWATER SUSTAINABILITY PLAN Dear Fritz Buchman:

The California Department of Fish and Wildlife (Department) is providing comments on the 2024 Eastern San Joaquin Groundwater Sustainability Plan Amendment (Amended GSP) made available to the public on October 1, 2024 and prepared pursuant to the Sustainable Groundwater Management Act (SGMA). The Basin is designated as Critically Over Drafted under SGMA.

The Department is writing to support ecosystem preservation and enhancement in compliance with SGMA and its implementing regulations based on Department expertise and best available information and science. The Department has an interest in the sustainable management of groundwater, as many sensitive ecosystems, species, and public trust resources depend on groundwater and interconnected surface water (ISW), including groundwater dependent ecosystems (GDEs). In the context of SGMA statutes and regulations, and Public Trust Doctrine considerations, groundwater planning should carefully consider and protect environmental beneficial uses and users of groundwater, including fish and wildlife and their habitats, GDEs, and ISW. The Department has enclosed, for reference, a summary of GSP requirements and GSA obligations with respect to the protection of fish and wildlife and public trust resources (Attachment A).

COMMENTS AND RECOMMENDATIONS
The Department reviewed the Eastern San Joaquin Amended GSP and believes that it fails to adequately address the following two Recommended Corrective Actions identified in the Department of Water Resources (DWR) Approval Determination:

DWR Recommended Corrective Action 1b: The GSP should include a more thorough evaluation of the impacts to environmental uses and users related to the groundwater level minimum thresholds, or, at minimum, describe a plan to perform this evaluation in the future when additional data becomes available.

Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Fritz Buchman
Eastern San Joaquin Subbasin
October 30, 2024

Page 2 ends

Conserving California’s Wildlife Since 1870
Amended GSP: A response to Recommended Corrective Action 1 is provided in Appendix 3-C of the Amended GSP. Through use of the same GDE mapping methodology included in the 2020 GSP, a count of GDE polygons was generated for the subbasin. For each representative monitoring well for the Chronic Lowering of Groundwater Levels Sustainable Management Criteria (SMC), an “impact zone” within a 3-mile radius of the well was delineated. The Amended GSP modeled groundwater levels at Minimum Thresholds, assessed which impact zones would experience groundwater levels more than 30 feet below the ground surface, and computed what percentage of GDEs within the subbasin would lose access to groundwater resources.

Department Response and Recommendation: The Department appreciates the effort to more thoroughly consider impacts to GDEs that may occur at the identified SMC for Chronic Lowering of Groundwater Levels. After reviewing the Amended GSP, the Department provides the following responses and recommendations:
a. Appendix 3-C Figures 6, 7, and 8 show examples of the GDE impact zone assessment. The inset map in each figure shows an overlay of the groundwater level monitoring network, the impact zone of each well, and the location of GDEs within the subbasin. It appears that a high proportion of GDEs within the subbasin are not located sufficiently close to a monitoring well to be within an analyzed impact zone, particularly in the northwestern portion of the subbasin and along the western boundary. It is therefore unclear to what extent, if any, the groundwater levels underlying these GDEs have been modeled or considered in the impact analysis presented in the Amended GSP. Without an associated monitoring well that can be used to assess whether or not groundwater levels in these areas would decline below the root zone of GDEs, the analysis and statistics presented in the Amended GSP stating that only a small percentage of GDEs would be impacted during a subbasin Undesirable Result scenario is insufficient and risks underestimating impacts to GDEs. The Department recommends the Amended GSP clearly identify the lack of monitoring wells sufficiently close to identified GDEs as a data gap and propose an actionable path to resolve the data gap. While the Amended GSP describes vague plans to install additional shallow monitoring wells in the future, the plan should provide a specific timeline for addressing this data gap.
b. The Amended GSP acknowledges that the GDE analysis completed was a desktop review, and field identification and verification of vegetated and wetland GDEs and associated wildlife is warranted. This data gap and need was also identified in the 2020 GSP, however no timeline or specific project or management action associated with GDE field verification was readily apparent in the Amended GSP. The Department recommends including GDE field identification and verification as a project and management action, with an associated timeline for implementation.

Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Fritz Buchman
Eastern San Joaquin Subbasin
October 30, 2024

Page 3 ends

Conserving California’s Wildlife Since 1870
c. Appendix 3-C of the Amended GSP, when describing the GDEs located within impact zones shown in Figures 6, 7, and 8, states that if a potential GDE is proximate to irrigated agriculture or surface water sources that may provide some level of water supply to the potential GDE, that ecosystem may not be considered a GDE. This perpetuates a false dichotomy and incorrect assumption that GDEs must rely solely on groundwater in order to be considered groundwater dependent; instead, GDEs may rely on groundwater for a portion of their water needs and may rely on groundwater to varying degrees depending on water year type and relative water availability from surface or groundwater sources. The Department recommends that this language be updated accordingly or removed from the Amended GSP.

DWR Recommended Corrective Action 6: The following items related to Depletions of Interconnected Surface Water by the first periodic evaluation:

1. Establish undesirable results, minimum thresholds, and measurable objectives consistent with GSP regulations. Quantify the location, quantity, and timing of depletions of interconnected surface water due to groundwater extraction.

2. Continue to fill data gaps, collect additional monitoring data, and implement the current strategy to manage depletions of interconnected surface water and define segments of interconnectivity and timing. The monitoring network should be updated to reflect any corresponding changes and approaches.

3. Prioritize collaborating and coordinating with local, state, and federal regulatory agencies as well as interested parties to better understand the full suite of beneficial uses and users that may be impacted by pumping induced surface water depletion within the GSA’s jurisdictional area.

Amended GSP: A response to Recommended Corrective Action 6 is provided in Appendix 3-G of the Amended GSP. The Amended GSP methodology identifies ISW by comparing modeled monthly groundwater conditions from the historic calibration scenario to streambed elevations. ISW are defined as surface water bodies in which groundwater levels are at or above the streambed elevation at least 75% of the time.

The Amended GSP sets ISW SMC at the same levels as the SMC for Chronic Lowering of Groundwater Levels and provides figures that compare the spatial extent of ISW connectivity, annual gains and losses, and seasonal gains and losses for both 2015 and an increased pumping, minimum threshold scenario as justification that the selected thresholds are protective.

Department Response and Recommendation: The Department appreciates the additional analysis and information provided for ISW in the Amended GSP. After reviewing the Amended GSP, the Department provides the following responses and recommendations:

Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Fritz Buchman
Eastern San Joaquin Subbasin
October 30, 2024

Page 4 ends

Conserving California’s Wildlife Since 1870
a. The Amended GSP does not provide context nor justification for requiring streams to be connected to groundwater at least 75% of the time to be considered ISW, as connectivity can vary seasonally and by water year type.

The Department recommends that the Amended GSP revise this connectivity threshold and include surface waters that may be connected only seasonally, or in wetter water year types, as ISW and include them in the subsequent analysis. Discounting streams connected less than 75% of the time as ISW risks failure to characterize and protect ISW GDEs with corresponding Minimum Thresholds that may be critical to aquatic and riparian species.

The Amended GSP also states that many smaller creeks and streams are used for the conveyance of irrigation water and are therefore not considered in the analysis of depletions. The Amended GSP does not provide specifics or rationale for this decision. The use of streams and creeks as conveyance does not preclude them from being ISW, particularly outside of the typical irrigation season when depletions may have relatively higher impacts to flows and instream temperatures. The Department recommends the Amended GSP identify what thresholds for irrigation conveyance were used to remove streams and creeks from the analysis, identify where they are located, and identify them as a data gap for improved ISW analysis in the future. b. In DWR’s 2023 Determination Letter for the Resubmitted Eastern San Joaquin GSP, DWR stated that the Resubmitted GSP did not quantify what would be considered an undesirable result in terms of stream depletion.

Rather than defining groundwater level thresholds that could cause undesirable results, the GSP suggests that the Chronic Lowering of Groundwater Levels SMC would preemptively protect against stream depletion undesirable results.

The Department does not believe that the Amended GSP adequately addresses and corrects this deficiency identified by DWR. Though the Amended GSP updates the ISW analysis to compare depletions estimated in 2015 to projected conditions at the minimum thresholds, the Amended GSP does not ever independently describe what would constitute an undesirable result for depletions of ISW. Instead, it presents metrics showing the relative change in depletions between the two scenarios, and though some segments experience increases in depletions beyond 2015 conditions, the changes are considered too small to constitute an undesirable result, though that undesirable result has not been otherwise defined. Additionally, the statistics presented are on a seasonal basis rather than a monthly basis, and the depletion values are aggregated for the entire length of each river through the subbasin which is too coarse a geography to meaningfully evaluate potential adverse impacts to ISW.

Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Fritz Buchman
Eastern San Joaquin Subbasin
October 30, 2024

Page 5 ends

Conserving California’s Wildlife Since 1870
The Department recommends that the Amended GSP be updated with a definition of what would constitute an undesirable result for depletions of ISW that is independent of modeled changes based on the groundwater level SMC. The undesirable result definition should describe the rate, timing, and volume of depletions of ISW.

Additionally, a table presenting the baseline and projected scenario accretions and depletions by month, rather than in a figure showing quarterly values, would provide a higher resolution of information for review that is necessary for evaluating undesirable results to environmental beneficial users. As noted in the Amended GSP, some ISW within the subbasin experience markedly different depletion and accretion conditions in their upper vs lower reaches. Aggregating gains and losses across an entire river, rather than in more discrete segments, can mask localized adverse impacts to ISW in which specific segments may experience a significant increase in the rate of depletions, or decrease in the rate of accretions, that are not immediately evident when added together. The Department recommends separating ISW such as the Mokelumne River, Stanislaus River, Dry Creek, and the San Joaquin River into multiple segments and reporting modeled monthly depletion volumes for each.
c. The Amended GSP states that no undesirable results for ISW were occurring in 2015 in the subbasin because minimum instream flow requirements and agreements were met, and Chinook salmon populations were recovering after a decline in the late 2000s. Neither of these claims is evidence that demonstrates a lack of undesirable results due to depletions occurring in the subbasin.

Stream gauge compliance points located both upstream and downstream of the subbasin are used to inform surface water releases and allowable diversions to ensure that instream flow requirements and agreements are met. If significant depletions were occurring within the subbasin, additional surface water would be released, or diverters would bypass flow, to continue to maintain the required instream flows and offset the depletions.

Further, population dynamics of Chinook salmon are complex, variable, and not dependent solely on streamflow depletions. Streamflow, timing of pulse or attractant flows, water quality and temperature, habitat availability, and management actions all play a role in population numbers that are expected to vary from year to year. Presenting a single year of population data, which does not consider survival rates or spawning success, as evidence that depletions were not affecting aquatic users of ISW is overly simplistic and inappropriate.

The Department recommends the statements referenced above be removed from the Amended GSP. The Amended GSP should determine what rates, Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Fritz Buchman
Eastern San Joaquin Subbasin
October 30, 2024

Page 6 ends

Conserving California’s Wildlife Since 1870
timing, and volumes of depletion of ISW would be considered an undesirable result (see above comment on defining ISW undesirable results). d. The Department appreciates the work involved in installing 6 new monitoring wells within the subbasin that are now included as part of the ISW monitoring network. The Amended GSP states that due to the lack of historic groundwater level data, there are not yet any SMC thresholds identified for these six ISW wells. At least 4 years of data will need to be collected before SMC can be determined, but additional years of data collection may be required if one wet and one dry/critically dry year to not occur within those first 4 years.

The Department acknowledges the challenges associated with the lack of measured groundwater level data at these 6 wells. However, the Amended GSP identifies only 12 wells as part of the ISW monitoring well network; for at least 4 more years, 6 of the 12, or half of the monitoring network, will not have any SMC defined. Should the required wet and dry hydrology not occur in those 4 years, the lack of SMC could stretch even further. Given the need to reach sustainability by 2040, this level of delay in determining SMC for half of the ISW monitoring network is not acceptable and would prevent identification of undesirable results for ISW should they occur. The northern portion of the subbasin, where 5 of the 6 new wells are located, would be particularly susceptible to having unidentified undesirable results occur due to the lack of SMC. The Department recommends the Amended GSP include an interim methodology for establishing SMC at the 6 new monitoring wells included in the ISW network, that will be refined with additional years of data collection. e. The Department acknowledges that additional guidance from DWR on techniques for estimating depletions of ISW was not available prior to development of the Amended GSP. The Draft DWR guidance is now available for public review, and it encourages the use of numerical modeling to determine the depletion of ISW that is specifically attributable to groundwater pumping. The Amended GSP states that comparing modeled pumping and no-pumping scenarios using the most updated model for the Eastern San Joaquin subbasin was attempted, but it resulted in an inconclusive understanding and was therefore not incorporated into this Amended GSP.

The Department recommends the Amended GSP include specific, time-based plans to develop numerical model scenarios in accordance with DWR resources, define the ISW undesirable result, and develop protective SMC.

Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Fritz Buchman
Eastern San Joaquin Subbasin
October 30, 2024

Page 7 ends

Conserving California’s Wildlife Since 1870

CONCLUSION
In conclusion, the Department appreciates the updated analyses included in the Amended GSP, but the plan still needs improvement in its consideration of GDEs, ISW, and environmental beneficial uses and users of groundwater including fish and wildlife and their habitats. The Department’s comments further indicate that the Amended GSP fails to sufficiently address deficiencies previously identified by DWR, and thus may still include deficiencies in the following areas:

2. The GSP does not identify reasonable measures and schedules to eliminate data gaps [Cal. Code Regs., tit. 23, § 355.4, subd. (b)(2)];

The Department has included a summary of GSP regulatory requirements pertaining to the protection of fish and wildlife (Attachment A) and has also included prior Department comments (Attachments B, C, and D) for your reference.

The Department appreciates the opportunity to provide comments on the Eastern San Joaquin Basin Updated GSP. If you have any further questions or would like to discuss the Department’s comments, please contact [email protected].

Sincerely,
Morgan Kilgour
Regional Manager, North Central Region
Enclosures (Attachments A, B, C, D)
Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Fritz Buchman
Eastern San Joaquin Subbasin
October 30, 2024

Page 8 ends

Conserving California’s Wildlife Since 1870
ec: California Department of Fish and Wildlife
Brooke Jacobs, Branch Chief
Water Branch
[email protected]
Robert Holmes, Environmental Program Manager
Statewide Water Planning Program
[email protected]
Adam Weinberg, Statewide SGMA Coordinator
Groundwater Program
[email protected]
Briana Seapy, Water Program Supervisor
North Central Region
[email protected]
Jennifer Garcia, Environmental Program Manager
North Central Region
[email protected]
Bridget Gibbons, Regional SGMA Coordinator
North Central Region
[email protected]
California Department of Water Resources
Chelsea Spier, Eastern San Joaquin SGMA Point of Contact North Central Region Office
[email protected]
National Marine Fisheries Service
Rick Rogers, Fish Biologist
West Coast Region
[email protected]
State Water Resources Control Board
Natalie Stork, Assistant Director
Office of Sustainable Groundwater Management
[email protected]
Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Attachment A
Summary of GSP Requirements and GSA Obligations with Respect to the Protection of Fish and Wildlife and Public Trust Resources As trustee agency for the State’s fish and wildlife resources, the Department has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and the habitat necessary for biologically sustainable populations of such species (Fish & G. Code, §§ 711.7 and 1802). SGMA and its implementing regulations afford ecosystems and species specific statutory and regulatory consideration, including the following as pertinent to GSPs:
• GSPs must consider impacts to GDEs (Water Code, § 10727.4, subd. (l); see also Cal. Code Regs., tit. 23, § 354.16, subd. (g));
• GSPs must consider the interests of all beneficial uses and users of groundwater, including environmental users of groundwater (Water Code, § 10723.2) and GSPs must identify and consider potential effects on all beneficial uses and users of groundwater (Cal. Code Regs., tit. 23, §§ 354.10, subd. (a), 354.26, subd. (b)(3), 354.28, subd. (b)(4), 354.34, subds. (b)(2), & (f)(3));
• GSPs must establish sustainable management criteria that avoid undesirable results within 20 years of the applicable statutory deadline, including depletions of ISW that have significant and unreasonable adverse impacts on beneficial uses of the surface water (Cal. Code Regs., tit. 23, § 354.22 et seq. and Water Code §§ 10721, subd. (x)(6) and 10727.2, subd. (b)) and describe monitoring networks that can identify adverse impacts to beneficial uses of ISW (Cal. Code Regs., tit. 23, § 354.34, subd. (c)(6)(D)); and • GSPs must account for groundwater extraction for all water use sectors, including managed wetlands, managed recharge, and native vegetation (Cal.

Code Regs., tit. 23, §§ 351, subds. (a) & (l) and 354.18, subd. (b)(3)).

Furthermore, the Public Trust Doctrine imposes a related but distinct obligation to consider how groundwater management affects public trust resources, including navigable surface waters and fisheries. Groundwater hydrologically connected to surface waters is also subject to the Public Trust Doctrine to the extent that groundwater extractions or diversions affect or may affect public trust uses. (Environmental Law Foundation v. State Water Resources Control Board (2018), 26 Cal. App. 5th 844; National Audubon Society v. Superior Court (1983), 33 Cal. 3d 419.) The GSA has “an affirmative duty to take the public trust into account in the planning and allocation of water resources, and to protect public trust uses whenever feasible.” (National Audubon Society, supra, 33 Cal. 3d at 446.) Accordingly, groundwater plans should consider potential impacts to and appropriate protections for ISW and their tributaries, and ISW that support fisheries, including the level of groundwater contribution to those waters.

Conserving California’s Wildlife Since 1870
Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Conserving California’s Wildlife Since 1870
Attachment B

CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS ON THE EASTERN SAN

JOAQUIN REVISED GROUNDWATER SUSTAINABILITY PLAN
Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director North Central Region
1701 Nimbus Road
Rancho Cordova, CA 95670
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
September 29, 2022
Via Electronic Mail and Online Submission
Monica Reis, Supervising Water Resources Engineer
California Department of Water Resources
715 P Street, 8th Floor
Sacramento, CA 95814
Email: [email protected]
Portal Submission: https://sgma.water.ca.gov/portal/#gsp Fritz Buchman, C.E, T.E., CFM
Eastern San Joaquin Groundwater Authority
1810 E. Hazelton Avenue
Stockton, CA 95210
Email: [email protected]
Dear Monica Reis and Fritz Buchman:

Subject: CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS ON THE

EASTERN SAN JOAQUIN SUBBASIN REVISED GROUNDWATER SUSTAINABILITY PLAN
The California Department of Fish and Wildlife (Department) is providing comments on the Eastern San Joaquin Subbasin Revised Groundwater Sustainability Plan (Revised GSP) prepared by the Eastern San Joaquin Groundwater Authority (ESJGA)1 pursuant to the Sustainable Groundwater Management Act (SGMA) and submitted to the California Department of Water Resources (DWR) on January 28, 2022. The Subbasin is designated as a Critically Overdrafted, High Priority subbasin under SGMA. In response to the Department of Water Resources (DWR) Incomplete Determination, the GSA must submit the Revised GSP and other required information and materials to DWR by July 27, 2022.
1 The Eastern San Joaquin Groundwater Authority comprises 17 Groundwater Sustainability Agencies (GSAs):

Calaveras County Water District / Stanislaus County, California Water Service Company, Central Delta Water Agency, Central San Joaquin Water Conservation District, City of Lathrop, City of Lodi, City of Manteca, City of Stockton, Linden County Water District, Lockeford Community Services District, North San Joaquin Water Conservation District, Oakdale Irrigation District, San Joaquin County, South Delta Water Agency, South San Joaquin Groundwater Sustainability Agency, Stockton East Water District, and Woodbridge Irrigation District GSA.

DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Monica Reis, Supervising Engineer
California Department of Water Resources
September 29, 2022

Page 2 ends

The Department is writing to support ecosystem preservation and enhancement in compliance with SGMA and its implementing regulations based on Department expertise and best available information and science. As trustee agency for the State’s fish and wildlife resources, the Department has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and the habitat necessary for biologically sustainable populations of such species (Fish & Game Code §§ 711.7 and 1802).

Development and implementation of GSPs under SGMA represents a new era of California groundwater management. The Department has an interest in the sustainable management of groundwater, as many sensitive ecosystems, species, and public trust resources depend on groundwater and interconnected surface water (ISW).

SGMA and its implementing regulations afford ecosystems and species specific statutory and regulatory consideration, including the following as pertinent to GSPs:
• GSPs must consider impacts to groundwater dependent ecosystems (GDEs) (Water Code § 10727.4(l); see also 23 CCR § 354.16(g)); • GSPs must consider the interests of all beneficial uses and users of groundwater, including environmental users of groundwater (Water Code § 10723.2) and GSPs must identify and consider potential effects on all beneficial uses and users of groundwater (23 CCR §§ 354.10(a), 354.26(b)(3), 354.28(b)(4), 354.34(b)(2), and 354.34(f)(3)); • GSPs must establish sustainable management criteria that avoid undesirable results within 20 years of the applicable statutory deadline, including depletions of ISW that have significant and unreasonable adverse impacts on beneficial uses of the surface water (23 CCR § 354.22 et seq. and Water Code §§ 10721(x)(6) and 10727.2(b)) and describe monitoring networks that can identify adverse impacts to beneficial uses of ISW (23 CCR § 354.34(c)(6)(D)); and
• GSPs must account for groundwater extraction for all water use sectors, including managed wetlands, managed recharge, and native vegetation (23 CCR §§ 351(al) and 354.18(b)(3)).

In the context of SGMA statutes and regulations, and Public Trust Doctrine considerations, groundwater planning should carefully consider and protect environmental beneficial uses and users of groundwater, including fish and wildlife and their habitats, GDEs, and ISW.

Page 3 ends

Foundation v. State Water Resources Control Board (2018), 26 Cal. App. 5th 844; National Audubon Society v. Superior Court (1983), 33 Cal. 3d 419.) The GSA has “an affirmative duty to take the public trust into account in the planning and allocation of water resources, and to protect public trust uses whenever feasible.” (National Audubon Society, supra, 33 Cal. 3d at 446.) Accordingly, groundwater plans should consider potential impacts to and appropriate protections for ISW and their tributaries, and ISW that support fisheries, including the level of groundwater contribution to those waters.

The Department is providing comments and recommendations on the Eastern San Joaquin Subbasin Revised GSP (Attachment A). The comments in Attachment A only reflect those issues that DWR directed the GSA to address in its Incomplete Determination, and do not encompass all previous Department comments, many of which remain unresolved. For additional background, the Department is providing prior comments on the Final GSP as Attachment B, and prior comments on the Draft GSP as Attachment C.

As detailed in Attachment A, the Department believes that the Revised GSP does not address all the deficiencies identified by DWR in its Incomplete Determination. The Revised GSP does not adequately consider environmental users of groundwater or ISW. Accordingly, the Department continues to recommend ESJGA characterize impacts to environmental users and subsequently reselect minimum thresholds and measurable objectives that will avoid undesirable results for environmental users.

The Department appreciates the opportunity to provide comments on the Eastern San Joaquin Subbasin Revised GSP. If you have any further questions, please contact Tiffanee Hutton by email at [email protected].

Sincerely,
Kevin Thomas
Regional Manager, North Central Region
Enclosures (Attachments A, B)
ec: California Department of Fish and Wildlife
Brooke Jacobs, Acting Branch Chief
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Monica Reis, Supervising Engineer
California Department of Water Resources
September 29, 2022

Page 4 ends

Water Branch
[email protected]
Robert Holmes, Environmental Program Manager
Statewide Water Planning Program
[email protected]
Angela Murvine, Statewide SGMA Coordinator
Groundwater Program
[email protected]
Jennifer Garcia, Environmental Program Manager
North Central Region
[email protected]
Briana Seapy, Water Program Supervisor
North Central Region
[email protected]
Tiffanee Hutton, Regional SGMA Coordinator
North Central Region
[email protected]
California Department of Water Resources
Paul Wells, Eastern San Joaquin Subbasin SGMA Point of Contact North Central Region Office
[email protected]
National Marine Fisheries Service
Rick Rogers, Fish Biologist
West Coast Region
[email protected]
State Water Resources Control Board
Natalie Stork, Chief
Groundwater Management Program
[email protected]
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Monica Reis, Supervising Engineer
California Department of Water Resources
September 29, 2022

Page 5 ends

Attachment A

CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS ON THE EASTERN SAN

JOAQUIN SUBBASIN REVISED GROUNDWATER SUSTAINABILITY PLAN

COMMENTS AND RECOMMENDATIONS
DWR’s January 28, 2022 Incomplete Determination of the 2020 Eastern San Joaquin Groundwater Sustainability Plan (Incomplete Determination) identified two deficiencies and a total of nine associated corrective actions that needed to be addressed by the ESJGA prior to DWR determining the plan to be complete. The Department reviewed the Revised GSP and believes that the revision fails to adequately address the following portions of Deficiency 1 and Corrective Action 1d (Incomplete Determination):

Deficiency 1: The GSP also lacks sufficient explanation for its minimum thresholds and undesirable results for chronic lowering of groundwater levels.

Corrective Action 1d: The GSAs should also explain how other factors they identified as “potential undesirable results” (e.g., adverse impacts to environmental uses and users) were considered when developing and selecting minimum thresholds and describe anticipated effects of the thresholds on beneficial uses and users of groundwater.

Revised GSP Response to Corrective Action 1d: The Department reviewed sections

3.3.2 Sustainable Management Criteria; Chronic Lowering of Groundwater Levels and

3.3.6 Sustainable Management Criteria; Depletions of Interconnected Surface Water in the Revised GSP, looking for additional rationale that would demonstrate the minimum thresholds selected for chronic lowering of groundwater levels, and by proxy, the depletion of interconnected surface water, were developed with a consideration of environmental beneficial users and were determined to be protective against adverse impacts. No changes were made in the primary text of the Revised GSP in either section that relate to environmental users of groundwater; the Revised GSP instead states that additional explanations related to Corrective Action 1d can be found in Appendix 3-D, which contains Technical Memorandum No. 2 – Drinking Water and Shallow Wells.

Department Response and Recommendation: Upon review of the information provided in Appendix 3-D, the Department believes that the rationale provided in the Revised GSP remains insufficient in its consideration of environmental users of groundwater. In DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Monica Reis, Supervising Engineer
California Department of Water Resources
September 29, 2022

Page 6 ends

the subsection of Appendix 3-D that purportedly provides a response to the sentence of Corrective Action 1d outlined above, the appendix makes no mention of environmental users of groundwater, including groundwater dependent ecosystems or interconnected surface water, as specifically recommended by DWR in its Incomplete Determination.

Appendix 3-D largely restates the rationale provided in the main text of the GSP, in which the identification of minimum thresholds and measurable objectives relies on the unsubstantiated assertion that groundwater levels within the subbasin can continue to decline without environmental users of groundwater experiencing significant and unreasonable undesirable results, a statement which is incongruous with DWR’s identification of the subbasin as critically overdrafted.

Low flows and increased water temperatures in the lower San Joaquin River have been documented to negatively impact Chinook salmon (Oncorhynchus tshawytscha) and steelhead (Oncorhynchus mykiss) (Hallock 1970, Marston 2012). 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.

As previously stated in the Department’s comments on both the Final (Attachment B) and Draft (Attachment C) GSPs, the Department recommends that the ESJGA complete a thorough assessment of the potential adverse impacts to environmental beneficial users and reselect minimum thresholds and measurable objectives that would be protective of environmental beneficial users of groundwater and interconnected surface water.

CONCLUSION
In conclusion, the Department believes the Revised GSP warrants a determination of inadequacy because deficiencies identified by DWR have not been corrected prior to the applicable statutory deadline (23 CCR § 355.2(e) and 355.4(a)). The Revised GSP neither presents a rationale that explains how environmental users were considered in the methodology for determining sustainability criteria, nor does it include analysis that demonstrates that environmental users would be protected from undesirable results by the identified minimum thresholds and measurable objectives. As described above, the Department’s comments indicate that the Revised GSP fails to sufficiently address the following:

Page 7 ends

2. The sustainable management criteria and projects and management actions are not commensurate with the level of understanding of the basin setting, based on the level of uncertainty, as reflected in the GSP. [23 CCR § 355.4(b)(3)]

3. The interests of the beneficial uses and users of groundwater in the basin, and the land uses and property interests potentially affected by the use of groundwater in the basin, have not been considered. [23 CCR § 355.4(b)(4)] DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Attachment B

COMMENTS ON THE FINAL EASTERN SAN JOAQUIN SUBBASIN

GROUNDWATER SUSTAINABILITY PLAN
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Natural Resources Agency GAVIN NEWSOM, Governor
DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director North Central Region
1701 Nimbus Road,
Rancho Cordova, CA 95670
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
May 13, 2020
Via Electronic Mail and Online Submission
Craig Altare
Supervising Engineering Geologist
California Department of Water Resources
901 P Street, Room 213
Sacramento, CA 94236
Email: [email protected]
Portal Submission: https://sgma.water.ca.gov/portal/#gsp Dear Mr. Altare:

Subject: COMMENTS ON THE FINAL EASTERN SAN JOAQUIN SUBBASIN

GROUNDWATER SUSTAINABILITY PLAN
The California Department of Fish and Wildlife (Department) North Central Region is providing comments on the Final Eastern San Joaquin Subbasin Groundwater Sustainability Plan (GSP) prepared by the Eastern San Joaquin Groundwater Authority (ESJGA)1 pursuant to the Sustainable Groundwater Management Act (SGMA). As trustee agency for the State’s fish and wildlife resources, the Department has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and the habitat necessary for biologically sustainable populations of such species (Fish & Game Code §§ 711.7 and 1802).

Development and implementation of GSPs under SGMA represents a new era of California groundwater management. The Department has an interest in the sustainable management of groundwater, as many sensitive ecosystems and species depend on groundwater and interconnected surface waters, including ecosystems on Departmentowned and -managed lands within SGMA-regulated basins. SGMA and its implementing regulations afford ecosystems and species specific statutory and regulatory consideration, including the following as pertinent to Groundwater Sustainability Plans:
1 The Eastern San Joaquin Groundwater Authority comprises 17 Groundwater Sustainability Agencies (GSAs):

DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 2 of 14 ends

Conserving California’s Wildlife Since 1870
• Groundwater Sustainability Plans must identify and consider impacts to groundwater dependent ecosystems (GDEs) [23 CCR § 354.16(g) and Water Code § 10727.4(l)];
• Groundwater Sustainability Agencies must consider all beneficial uses and users of groundwater, including environmental users of groundwater [Water Code §10723.2 (e)]; and Groundwater Sustainability Plans must identify and consider potential effects on all beneficial uses and users of groundwater [23 CCR §§ 354.10(a), 354.26(b)(3), 354.28(b)(4), 354.34(b)(2), and 354.34(f)(3)];
• Groundwater Sustainability Plans must establish sustainable management criteria that avoid undesirable results within 20 years of the applicable statutory deadline, including depletions of interconnected surface water that have significant and unreasonable adverse impacts on beneficial uses of the surface water [23 CCR § 354.22 et seq. and Water Code §§ 10721(x)(6) and 10727.2(b)] and describe monitoring networks that can identify adverse impacts to beneficial uses of interconnected surface waters [23 CCR § 354.34(c)(6)(D)]; and
• Groundwater Sustainability Plans must account for groundwater extraction for all water use sectors including managed wetlands, managed recharge, and native vegetation [23 CCR §§ 351(al) and 354.18(b)(3)].

Furthermore, the Public Trust Doctrine imposes a related but distinct obligation to consider how groundwater management affects public trust resources, including navigable surface waters and fisheries. Groundwater hydrologically connected to navigable surface waters or surface waters supporting fisheries, and surface waters tributary to navigable surface waters or surface waters supporting fisheries, are also subject to the Public Trust Doctrine to the extent that groundwater extractions or diversions affect or may affect public trust uses (Environmental Law Foundation v. State Water Resources Control Board (2018), 26 Cal. App. 5th 844; National Audubon Society v. Superior Court (1983), 33 Cal. 3d 419). Accordingly, groundwater plans should consider potential impacts to and appropriate protections for interconnected surface waters and their tributaries, and interconnected surface waters that support fisheries, including the level of groundwater contribution to those waters.

In the context of SGMA statutes and regulations, and Public Trust Doctrine considerations, the Department values groundwater planning that carefully considers and protects environmental beneficial uses and users of groundwater including fish and wildlife and their habitats: groundwater dependent ecosystems and interconnected surface waters.

COMMENT OVERVIEW
The Department supports ecosystem preservation and enhancement in compliance with SGMA and its implementing regulations based on Department expertise and best DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 3 of 14 ends

Conserving California’s Wildlife Since 1870
available information and science. Consistent with comments previously submitted to the GSA on August 23, 2019, the Department recommends the GSP provide additional information and analysis that considers all environmental beneficial uses and users of groundwater and that better characterizes surface water-groundwater connectivity. The Department appreciates ESJGA’s consideration and integration of many of the Department’s original comments. Where the Department’s initial comments have not been addressed, they are restated in this letter with updated page citations. Where ESJGA has since responded to the Department’s comments, the Department has updated the comments and provided additional context in italicized text.

COMMENTS AND RECOMMENDATIONS
The Department comments are as follows:

1. Comment #1 (Basin Setting, 2.2.6 Interconnected Surface Water Systems, starting page 2-104): The narrative describing the basin’s interconnected surface water (ISW) conditions lacks specifics.
a. Issue:
i. The interconnected surface water conditions narrative lacks estimations of the quantity and timing of streamflow depletions as required by 23 CCR § 354.16(f).
b. Recommendation:
i. Identify the estimated quantity and timing of streamflow depletions in the ESJ Subbasin. If this information is not available, delineate a specific and expeditious path to estimating these values.

GSA Response to Comments: “See Master Response 2 - ISW” (Appendix 1-J, PDF page 899).

Department Response: In response to ISW comments, ESJGA identified ISW as a data gap, specified the need for near-stream monitoring wells additional analysis/iterative modeling, clarified gaining/losing stream language and figures, and removed stream nodes with poor model calibration (among other responses). The Department appreciates these responsive GSP updates and the clear acknowledgement of ISW as a data gap. Though the above comment identifies an unmet GSP regulatory expectation, the Department understands data scarcity challenges and recommends ESJGA clearly identify how they will succeed in meeting this regulatory standard during GSP implementation.

2. Comment #2 (Basin Setting, 2.2.7 Groundwater-Dependent Ecosystems, starting page 2-108): GDE identification, required by 23 CCR § 354.16(g), is incomplete.

Page 4 of 14 ends

Conserving California’s Wildlife Since 1870
a. Issues: Use of the Natural Communities Commonly Associated with Groundwater (NCCAG) dataset to identify GDEs is incomplete. i. Incomplete GDE Description: The GSP notes, “GDEs exist where vegetation accesses shallow groundwater for survival. This Plan identifies GDEs within the Eastern San Joaquin Subbasin based on determining the areas where vegetation is dependent on
groundwater” (2-108). This cursory summation of GDEs excludes aquatic GDEs that rely on groundwater recharge to instream flow.

Further, the GDE methods section states, “The NCCAG database was then further refined to identify communities without access to alternate water supplies, as those communities would not be dependent on groundwater” (2-110). Presumably the word ‘not’ is included in error.
ii. GDE Identification Data Gap: In response to GDE comments on the Draft GSP, ESJGA identified several GDE assessments as data gaps rather than remove the potential GDEs from the dataset, which was the previous approach. These data gaps include potential GDEs where the depth to groundwater exceeds 30 feet (using a 2015 baseline) and potential GDEs with access to alternate water supplies (2-111). The GSP intends to refine these categories of potential GDEs via future analysis (2-110, 2-111), but the plan does not specify how. The Department reiterates its original concern for exclusion of GDEs based on a snapshot of groundwater elevation during a historical drought or based on the assumption that ecosystem water reliance is static, rather than fluid and able to tap into surface water and groundwater, conditiondependent. b. Recommendations:
i. Incomplete GDE Description: Include aquatic GDEs (i.e., ISW) in the narrative description of GDEs and confirm that ecological communities without access to surface water are groundwater dependent.
ii. GDE Data Gap Identification: Specify how ESJGA will refine GDE identification and resolve data gaps to comply with GSP regulations during GSP implementation.

GSA Response to Comments: “See Master Response 1 - GDEs” (Appendix 1-J, PDF page 898).

Department Response: In response to GDE comments, ESJGA updated GDE identification methods, adding language identifying NCCAG areas previously removed as data gaps that require further refinement. The Department appreciates these responsive GSP updates and the clear acknowledgement of GDE identification data gaps. The Department has updated the above comment accordingly, and though the above comment identifies an unmet GSP regulatory expectation, the Department understands data scarcity challenges and recommends the ESJGA clearly identify how DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 5 of 14 ends

Conserving California’s Wildlife Since 1870
they will succeed in meeting this regulatory standard during GSP implementation.

3. Comment #3 (Basin Setting, 2.3.5.3 Projected Water Budget, starting page 2- 138): Projected water budget assumptions may risk overestimating surface water availability and sustainable yield by not relying on best available information [23 CCR § 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, 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 do not reflect 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.

GSA Response to Comments: “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 DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 6 of 14 ends

Conserving California’s Wildlife Since 1870
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” (Appendix 1-J, PDF page 903).

Department Response: The Department appreciates the clarifying language and explanations provided in ESJGA’s above response. The Department believes the above comment remains relevant, particularly for future GSP updates and successful, realistic long-term GSP implementation.

4. Comment #4 (Sustainable Management Criteria, 3.2.1 Chronic Lowering of Groundwater Levels and 3.2.6 Depletions of Interconnected Surface Water, starting page 3-3): 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 Interconnected Surface Water. The GSP does not provide evidence that a “significant correlation exists between groundwater elevations” and Depletions of Interconnected Surface Water [23 CCR §
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 (page 3-22).

The GSP offers few details to substantiate this claim that historical surface water depletions did not lead to undesirable results, and the summarized modeling exercise used to determine the
insignificance of historical surface water depletions is based on a model with significant data gaps around surface water depletion functions (see Comment #1). Provided the status of surface water allocations and aquatic ecosystems on rivers in the ESJ basin, the DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 7 of 14 ends

Conserving California’s Wildlife Since 1870
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 (Oncorhynchus tshawytscha) 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 (pages 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 (nonDocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 8 of 14 ends

Conserving California’s Wildlife Since 1870
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 #4.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 GSP notes 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 (page 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 (page 3-8); and measurable objectives are set at historically low groundwater elevations (page 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 subbasin] would probably result in significant adverse overdraft-related environmental, social, or economic impacts” (CDWR). However, according to the GSP, there are no areas within the basin that are considered to have ‘significant and DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 9 of 14 ends

Conserving California’s Wildlife Since 1870
unreasonable existing issues’ (page 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 #4.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. Recommendations:
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 DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 10 of 14 ends

Conserving California’s Wildlife Since 1870
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. Consider how historical groundwater pumping has impacted stream interconnectivity (Figure 2-7, page 2-106), likely increasing streamflow depletion and reducing baseflows in ESJ Subbasin tributaries. Reduced groundwater baseflow exacerbates high water temperatures in the lower San Joaquin River, and high water temperatures 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.

GSA Response to Comments: “See Master Response 2 - ISW” (Appendix 1-J, PDF page 899).

Department Response: The above comment remains relevant.

5. Comment #5 (Monitoring Networks, starting page 4-1): Number, distribution, and frequency of data collection of shallow groundwater monitoring wells are insufficient for analysis of ISW.
a. Issue: The current monitoring network lacks a sufficient number, representative distribution, and frequency of monitoring 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; 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, which are impacted disproportionately by shallow groundwater trends.

Page 11 of 14 ends

Conserving California’s Wildlife Since 1870
b. Recommendation: Install additional shallow groundwater monitoring wells near GDEs and interconnected surface waters, potentially pairing multiplecompletion wells with streamflow gauges for improved understanding of surface water-groundwater interconnectivity. Monitor wells monthly to capture seasonal trends important to GDEs.

GSA Response to Comments: “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” (Appendix 1-J, PDF page 905).

Department Response: The anticipated monitoring network expansion will vastly improve data collection and monitoring. Until such time as the new system is in place, the Department maintains the above concern for insufficient monitoring. The Department will also continue to recommend monthly monitoring of shallow groundwater to better understand the relationships between shallow groundwater trends and fish and wildlife beneficial uses and users of groundwater.

6. Comment #6 (Project and Management Actions; 6.1 Projects, Management Actions, and Adaptive Management Strategies; starting page 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 DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 12 of 14 ends

Conserving California’s Wildlife Since 1870
flexibility to implement demand-side management in the future (page 6-1), there are no specifics as to how the ESJGA or subbasin GSAs 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 as a ‘Critically Overdrafted Basin’ and considering the cost and timing challenges associated with supply augmentation projects, a balanced portfolio approach to achieve groundwater sustainability should include demandmanagement 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 component of San Joaquin Valley long-term groundwater sustainability. Be specific about triggers, timing, and expected outcomes of demand-management actions.

GSA Response to Comments: “See Master Response 5 – Projects” (Appendix 1-J, PDF page 902)
Department Response: Master Response 5 includes the addition of new language in the GSP that promises to convene a working group if projects are not effective in achieving their target recharge or offset targets. The Department remains concerned that this action, in concert with the minimal demand-management actions, may be insufficient to achieve long term sustainability. Therefore, the above comment remains relevant.

CONCLUSION
In conclusion, the Final Eastern San Joaquin Basin GSP has improved GSP transparency by acknowledging several key data gaps. After thorough review, the Department deems the GSP insufficient in its consideration of environmental beneficial uses and users of groundwater, including fish and wildlife and their habitats: GDEs and ISW. The Department recommends that ESJGA address the Departments concerns before the California Department of Water Resources approves the final GSP.

The Department appreciates the opportunity to provide comments on the Final Eastern San Joaquin Basin GSP. If you have any further questions, please contact Briana Seapy by email at [email protected] or at (916) 508-3345.

Page 13 of 14 ends

Conserving California’s Wildlife Since 1870
Sincerely,
Kevin Thomas
Regional Manager, North Central Region
ec: Joshua Grover, [email protected]
Robert Holmes, [email protected]
Jeff Drongesen, [email protected]
Briana Seapy, [email protected]
California Department of Fish and Wildlife
ec’s: Continued on page 14
Paul Wells, [email protected]
California Department of Water Resources
Brandon Nakagawa, [email protected]
Groundwater Sustainability Agency
Rick Rogers, [email protected]
Erin Strange, [email protected]
National Marine Fisheries Service
Natalie Stork, [email protected]
State Water Resources Control Board
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 14 of 14 ends

Conserving California’s Wildlife Since 1870
Literature Cited
Barlow, P.M., and Leake, S.A. 2012. Streamflow depletion by wells—Understanding and managing the effects of groundwater pumping on streamflow. U.S. Geological Survey Circular 1376.

California Department of Water Resources (CDWR). 2018. Critically Overdrafted Basins. Available: https://water.ca.gov/Programs/Groundwater-Management/Bulletin118/Critically-Overdrafted-Basins.

Hallock, R.J., R.F. Elwell, D.H. Fry Jr. 1970. Migrations of adult king salmon Oncorhynchus tshawytscha in the San Joaquin Delta as demonstrated by the use of sonic tags. State of California. The Resources Agency. Department of Fish and Game.

Fish Bulletin 151.

Marston, D, C. Mesick, A. Hubbard, D. Stanton, S. Fortmann-Roe, S. Tsao. T. Heyne. 2012. Delta flow factors influencing stray rate of escaping adult San Joaquin River fallrun Chinook salmon (Oncorhynchus tshawytscha). San Francisco Estuary & Watershed Science.

DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Attachment C

COMMENTS ON THE DRAFT EASTERN SAN JOAQUIN SUBBASIN

DEPARTMENT OF FISH AND WILDLIFE
North Central Region
1701 Nimbus Road,
Rancho Cordova, CA 95670
www.wildlife.ca.gov
GAVIN NEWSOM. Governor
CHARLTON H. BONHAM, Director
August 23, 2019
Brandon Nakagawa
Eastern San Joaquin Groundwater Sustainability Plan Manager Eastern San Joaquin Groundwater Authority
1810 E. Hazelton Avenue
P.O. Box 1810
Stockton, CA 95201
Email: [email protected]
Subject: COMMENTS ON THE EASTERN SAN JOAQUIN SUBBASIN DRAFT

GROUNDWATER SUSTAINABILITY PLAN
Dear Mr. Nakagawa;
The California Department of Fish and Wildlife (Department) North Central Region is providing comments on the Eastern San Joaquin (ESJ) Subbasin Draft Groundwater Sustainability Plan (GSP) prepared by the Eastern San Joaquin Groundwater Authority (ESJGA)' pursuant to the Sustainable Groundwater Management Act (SGMA). As trustee agency for the State's fish and wildlife resources, the Department has jurisdiction over the conservation, protection, and management offish, wildlife, native plants, and the habitat necessary for biologically sustainable populations of such species (Fish & Game Code §§ 711.7 and 1802).

Development and implementation of GSPs under SGMA represents a new era of California groundwater management. The Department has an interest in the sustainable management of groundwater, as many sensitive ecosystems and species depend on groundwater and interconnected surface waters, including ecosystems on Departmentowned and -managed lands within SGMA-regulated basins. SGMA and its implementing regulations afford ecosystems and species specific statutory and regulatory consideration, including the following as pertinent to Groundwater Sustainability Plans:
^The Eastern San Joaquin GnaundwaterAuthority comprises 17 GroundwaterSustainability Agencies (GSAs):

Calaveras County Water District / Stanislaus County, Califomia Water Service Company, Central Delta Water Agency, Central San Joaquin Water Conservation District, City of Lathrop, City of Lodi, City of Manteca, City of Stockton. Linden County Water District, Lockefbrd Community Services District, North San Joaquin Water Conservation District, Oakdale Irrigation District, San Joaquin County, South Delta Water Agency, South San Joaquin Groundwater Sustainability Agency, Stockton East Water District, Woodbridge Inigation District GSA.

Conserving CciCifomia's ^iOCCife Since 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 2 of 14 ends

• Groundwater Sustainablllty Plans must identify and consider impacts to groundwater dependent ecosystems [23 CCR § 354.16(g) and Water Code § 10727.4(1)]: I
• Groundwater Sustainablllty Agencies must consider all beneficial uses and users of groundwater, including environmental users of groundwater [Water Code §10723.2 (e)]; and Groundwater Sustalnabili^y Plans must identify and consider potential effects on all beneficial uses and users of groundwater [23 CCR §§354.10(a). 354.26(b)(3). 354.28(b)(4),1354.34(b)(2). and 354.34(f)(3)];
• Groundwater Sustainability Plans must establish sustainable management criteria that avoid undesirable results within 20 years of the applicable statutory deadline, including depletions of interconnected surface water that have significant and unreasonable adverse impacts on beneficial uses of the surface water [23 CCR § 354.22 et seq. and Water Code §§ 10721(x)(6) and 10727.2(b)] and describe monitoring networl^s that can identify adverse impacts to beneficial uses of interconnected surface waters [23 CCR § 354.34(c)(6)(D)]: and • Groundwater Sustainability Plans must account for groundwater extraction for all Water Use Sectors including managed wetlancJs, managed recharge, and native vegetation [23 CCR §§ 351(al) and 354.18(b)(3)].

Accordingly, the Department values SGMA groundwater planning that carefully considers and protects groundwater dependent ecosystems (GDE), fish and wildlife beneficial uses, and users of groundwater and Interconnected surface waters.

COMMENT OVERVIEW
The Department Is writing to support ecosystem preservation In compliance with SGMA and its implementing regulations based on Department expertise and best available information and science.
!
The Department believes the GSP does not adequately demonstrate consideration of environmental beneficial uses and users of groundwater in its sustainablllty management criteria nor does It adequately characterize or consider surface watergroundwater connectivity. Accordingly, the Department recommends that ESJGA address these deficiencies before submitting the GSP to the Department of Water Resources(DWR). !

COMMENTS AND RECOMMENDATIONS
The Department comments are as follows:

1. Comment #1 (Plan Area, 1.2.1.1 Summary of Jurisdictlonal Areas and Other Features, pp. 1-18): Department lands are excluded from 'Summary of Jurisdictlonal Areas' narrative as well as from Figure 1-11, which maps other federal and state lands.

Conserving CaGfomia's WiQ£Cife Since 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 3 of 14 ends

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.

2. Comment #2 (Basin Setting, 2.2.6 Interconnected Surface Water Systems, starting pp 2-97): The nanrative 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. Ifthis information is not available, identify an expeditious path to estimating these values.
ii. Update Figure 2-66 to show all interconnected stream reaches, even ifthey are interconnected less than 25% of the time.

3. Comment #3 (Basin Setting, 2.2.7 Groundwater-Dependent Ecosystems, starting pp 2-100): 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.

Conserving CctRfomia's WiC(£Cife Since 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23. 2019

Page 4 of 14 ends

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-point-in-tinfie baseline hydrology.

Specifically, this 2015 baseline falls several years into a historic drought when groundwater levels throughout the San Joaquin Valley were trending dramatically lovier 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 apcess (Naumburg 2005), but that rely on groundwater table recovery for long term survival. ii. Adjacent to Alternate Water Suoplies: 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 feeit ofirrigated lands, 150 feet of managed wetlands, and 150feet of perennial surfacewaterdoes 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 'altemate water supplies' rely on groundwater during specific seasons or water years.
b. Recommendations:
i. Depth to Groundwater: Developa 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.
2The Department assumes that potential GDEs removed under this step overiie shallow groundwater, otherwise they would have already been removed during the step of excluding potential GDEs that overlie a depth to groundwater of 30+ feet.

Conserving California's WiCcCCifeSince 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 5 of 14 ends

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.

4. Comment #4 (Basin Setting, 2.3.5.4 Projected Water Budget, starting pp 2-130):

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 infomriation and that underscore cunrent 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 ofsurface 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 Southem 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.

5. Comment #5 (Sustainable Management Criteria, 3.2.1 Groundwater Levels and

3.2.6 Depletions of Interconnected Surface Water, starting pp 3-1): 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. Proxv Metric: Before addressing the individual sustainability criteria for both Groundwater Levels and Depletions of Interconnected Conserving CaCifomia's "WifdCife Since 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 6 of 14 ends

Surface Water, the Department challenges the use of groundwater elevations as a proxy metric for Depletions of Interconnected Surface 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-rlver 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 {Oncorhynchus tshawytscha) 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, particulariy 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 pooriy predict instream habitat Conserving CaRfomia's WitcCCife Since 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 7 of 14 ends

conditions for fish and wiidiife 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 (nondry) 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 GSP notes 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.

Page 8 of 14 ends

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 evenjmeasurable 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 Conserving California's ^ittCCifeSince 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 9 of 14 ends

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 informsustainability 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. ill. Minimum Thresholds and Measurable Obiectives: 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 likelycontributed to stream disconnection illustrated in figure 2-66 (GSP 2-99); resulting in depleted stream flows and reduced baseflows in ESJ Subbasin tributaries, and exacert3ated 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.

6. Comment #6 (Sustainable Management Criteria. 3.6 Degraded Water Quality, starting pp 3-10): 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).

Conserving California's WiCdCifeSince 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 10 of 14 ends

a. Issue'. Tlie 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 overpumping 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 occumng arsenic in groundwater, potentially increasing anthropjagenic and ecosystem exposure to arsenic contamination. According to SGIVIA statue, GSAs have the authorityto establish groundwaterjextractionallocations, 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 ESJGA 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 jregulatory programs by the first 5-year GSP update due in January 2025.

7. Comment #7 (Monitoring Networks, starting pp 4-jl): Number and distribution of groundwater monitoring wells are insufficient for analysis. a. Issue: The cun-ent monitoring network lack^ 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 fewdata 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 shallowj groundwater monitoring wells near GDEs and interconnected surface waters, potentially pairing multipleConsetving Cafifomia's WiUCCife Since 1870 DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 11 of 14 ends

completion wells with streamflow gauges for improved understanding of surface water-groundwater interconnectivity.

8. Comment #8 (Project and Management Actions; 6.1 Projects, Management Actions, and Adaptive Management Strategies: starting pp 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-tenn groundwater sustainability. Be specific about triggers, timing, and expected outcomes of demand-management actions.

CONCLUSION
In conclusion, the ESJ Subbasin Draft GSP does not comply with all aspects of SGMA statutes and regulations. The Department deems the GSP insufficient In its consideration of fish and wildlife beneficial uses and users of groundwater and interconnected surface waters. The Department recommends that ESJGA address the above comments before GSP submission to DWR. If these comments are not integrated, the Department may recommend to DWR an 'incomplete' or 'inadequate' plan detemninatlon based on the following regulatory criteria for plan evaluations:

1. The assumptions, criteria, findings, and objectives, including the sustainability goal, undesirable results, minimum thresholds, measurable objectives, and interim milestones are not reasonable and/or not supported by the best available infonnation and best available science. [23 OCR § 355.4(b)(1)] (See Comment #2, 3, 4, 5, 7)
Conserving CaCifomia's WilifCifeSince 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority j
August 23, 2019

Page 12 of 14 ends

2. The GSP does not identify reasonable measures and schedules to eliminate data gaps. [23 CCR § 355.4(b)(2)] (See Comment #7)

3. The sustainable management criteria and projects and management actions are not commensurate with the level of understanding of the basin setting, based on the level of uncertainty, as reflected in the GSP. [23 CCR § 355.4(b)(3)] (See Comment #5, 6, 8)

4. The interests of the beneficial uses and users of groundwater in the basin, and the land uses and property interests potentially affected by the use of groundwater in the basin, have not been considered. [23 CCR § 355.4(b)(4)] (See Comment #1. 2, 3, 4, 5, 7)

5. The projects and management actions are not feasible and/or not likely to prevent undesirable results and ensure that the basin is operated within its sustainable yield. [23 CCR § 355.4(b)(5)] (See Comment #8)

6. The GSP does not include a reasonable assessment of overdraft conditions and/or does not include reasonable means to mitigate overdraft, if present. [23 CCR § 355.4(b)(6)] (See Comment #4, 8)
The Department appreciates the opportunity to provide comments on the ESJ Subbasin Draft GSP. Please contact Lauren Mulloy by email at [email protected] with any questions.

Sincerely,
Kevin Thomas
Regional Manager. North Central Region
Enclosures (Literature Cited)
ec: California Department of Fish and Wildlife
Joshua Grover, Branch Chief
Water Branch
[email protected]
Robert Holmes, Environmental Program Manager
Statewide Water Planning Program
Robert. [email protected]
Briana Seapy, Statewide SGMA Coordinator
Groundwater Program
[email protected]
Conserving C<^fifomia's M/ifxfCife Since 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 13 of 14 ends

MaryLlsa Cornell, Water Unit Supervisor
North Central Region
[email protected]
Lauren Mulloy, Environmental Scientist
North Central Region
[email protected]
California Department of Water Resources
Craig Altare, Supervising Engineering Geologist
Sustainable Groundwater Management Program
[email protected]
Paul Wells, Eastern San Joaquin Subbasin SGMA Point of Contact North Central Region Office
[email protected]
National l\/1arine Fisheries Service
Rick Rogers, Fish Biologist
West Coast Region
[email protected]
Erin Strange, San Joaquin River Branch Lead
West Coast Region
[email protected]
State Water Resources Control Board
James Nachbaur, Director
Office of Research, Planning & Performance
[email protected]
Conserving CaCifomia's 'Pl/ilKCifeSince 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Brandon Nakagawa, ESJ GSP Plan Manager
Eastern San Joaquin Groundwater Authority
August 23, 2019

Page 14 of 14 ends

Literature Cited
Barlow, P.M., and Leake, S.A., 2012, Streamflow depletion by wells—Understanding and managing the effects of groundwater pumping on streamflow: U.S. Geological Survey Circular 1376.

California Department of Water Resources: Community Water Center. "Critically Overdrafted Basins." or httDs://water.ca.Qov/Proarams/GroundwaterManaaement/Bulletin-118/Criticallv-Overdrafted-Basins Hallock, R.J., R.F. Elwell, D.H. Fry Jr. 1970. Migrations of adult king salmon Oncorhynchus tshawytscha in the San Joaquin Delta as demonstrated by the use of sonic tags. State of California. The Resources Agency. Department of Fish and Game.

Fish Bulletin 151.

Marston, D, C. Mesick, A. Hubbard, D. Stanton, S. Fortmann-Roe, 8. Tsao. T. Heyne. 2012. Delta flow factors influencing stray rate of escaping adult San Joaquin River fallrun Chinook salmon (Oncorhynchus tshawytscha). San Francisco Estuary & Watershed Science.

Naumburg E, Mata-Gonzalez R, Hunter R.G.. McLendon T, Martin D.W. 2005. Phreatophytic vegetation and groundwater fluctuations: a review of current research and application of ecosystem response modeling with an emphasis on great basin vegetation. Environmental Management. 35(6);726-40.

Stanford: School of Earth, Energy & Environmental Sciences. "Groundwater Quality in the Sustainable Groundwater Management Act (SGMA): Scientific Factsheet on Arsenic, Uranium, and Chromium." or
httDs://d3n8a8Dro7vhmx.cloudfront.net/communitvwatercenter/paaes/293/attachments/o riainal/1560371896/CWC FS Gmdv/trQual 06.03.19a.odf?1560371896 Conserving California's "WilxlTife Since 1870
DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Attachment D

LITERATURE CITED
Hallock, R.J., R.F. Elwell, D.H. Fry Jr. 1970. Migrations of adult king salmon Oncorhynchus tshawytscha in the San Joaquin Delta as demonstrated by the use of sonic tags. State of California. The Resources Agency. Department of Fish and Game.

Fish Bulletin 151.

DocuSign Envelope ID: A151C829-1927-4575-B956-283E6FE204DE Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Conserving California’s Wildlife Since 1870
Attachment C

CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS ON THE EASTERN SAN

JOAQUIN FINAL GROUNDWATER SUSTAINABILITY PLAN
Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Natural Resources Agency GAVIN NEWSOM, Governor
DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director North Central Region
1701 Nimbus Road,
Rancho Cordova, CA 95670
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
May 13, 2020
Via Electronic Mail and Online Submission
Craig Altare
Supervising Engineering Geologist
California Department of Water Resources
901 P Street, Room 213
Sacramento, CA 94236
Email: [email protected]
Portal Submission: https://sgma.water.ca.gov/portal/#gsp Dear Mr. Altare:

Subject: COMMENTS ON THE FINAL EASTERN SAN JOAQUIN SUBBASIN

Development and implementation of GSPs under SGMA represents a new era of California groundwater management. The Department has an interest in the sustainable management of groundwater, as many sensitive ecosystems and species depend on groundwater and interconnected surface waters, including ecosystems on Departmentowned and -managed lands within SGMA-regulated basins. SGMA and its implementing regulations afford ecosystems and species specific statutory and regulatory consideration, including the following as pertinent to Groundwater Sustainability Plans:
1 The Eastern San Joaquin Groundwater Authority comprises 17 Groundwater Sustainability Agencies (GSAs):

Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 2 of 14 ends

Furthermore, the Public Trust Doctrine imposes a related but distinct obligation to consider how groundwater management affects public trust resources, including navigable surface waters and fisheries. Groundwater hydrologically connected to navigable surface waters or surface waters supporting fisheries, and surface waters tributary to navigable surface waters or surface waters supporting fisheries, are also subject to the Public Trust Doctrine to the extent that groundwater extractions or diversions affect or may affect public trust uses (Environmental Law Foundation v. State Water Resources Control Board (2018), 26 Cal. App. 5th 844; National Audubon Society v. Superior Court (1983), 33 Cal. 3d 419). Accordingly, groundwater plans should consider potential impacts to and appropriate protections for interconnected surface waters and their tributaries, and interconnected surface waters that support fisheries, including the level of groundwater contribution to those waters.

COMMENT OVERVIEW
The Department supports ecosystem preservation and enhancement in compliance with SGMA and its implementing regulations based on Department expertise and best Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 3 of 14 ends

COMMENTS AND RECOMMENDATIONS
The Department comments are as follows:

GSA Response to Comments: “See Master Response 2 - ISW” (Appendix 1-J, PDF page 899).

2. Comment #2 (Basin Setting, 2.2.7 Groundwater-Dependent Ecosystems, starting page 2-108): GDE identification, required by 23 CCR § 354.16(g), is incomplete.

Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 4 of 14 ends

GSA Response to Comments: “See Master Response 1 - GDEs” (Appendix 1-J, PDF page 898).

Department Response: In response to GDE comments, ESJGA updated GDE identification methods, adding language identifying NCCAG areas previously removed as data gaps that require further refinement. The Department appreciates these responsive GSP updates and the clear acknowledgement of GDE identification data gaps. The Department has updated the above comment accordingly, and though the above comment identifies an unmet GSP regulatory expectation, the Department understands data scarcity challenges and recommends the ESJGA clearly identify how Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 5 of 14 ends

Conserving California’s Wildlife Since 1870
they will succeed in meeting this regulatory standard during GSP implementation.

GSA Response to Comments: “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 Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 6 of 14 ends

The GSP offers few details to substantiate this claim that historical surface water depletions did not lead to undesirable results, and the summarized modeling exercise used to determine the
insignificance of historical surface water depletions is based on a model with significant data gaps around surface water depletion functions (see Comment #1). Provided the status of surface water allocations and aquatic ecosystems on rivers in the ESJ basin, the Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 7 of 14 ends

Conserving California’s Wildlife Since 1870
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 (Oncorhynchus tshawytscha) 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 (pages 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 (nonDocusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 8 of 14 ends

The ESJ Subbasin is characterized by DWR as ‘Critically Overdrafted,’ meaning “continuation of present water management practices [in the subbasin] would probably result in significant adverse overdraft-related environmental, social, or economic impacts” (CDWR). However, according to the GSP, there are no areas within the basin that are considered to have ‘significant and Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 9 of 14 ends

Conserving California’s Wildlife Since 1870
unreasonable existing issues’ (page 3-4), therefore minimum thresholds allow for continued groundwater depletions.

Specify undesirable result indicators for Depletions of Interconnected Surface Water that are relevant to beneficial users Docusign Envelope ID: F80B7DB6-AC32-48E0-A681-47F69EA5EC01 ATTACHMENT 2
Craig Altare, Supervising Engineering Geologist
California Department of Water Resources
May 13, 2020

Page 10 of 14 ends

Manteca City CouncilApril 15, 2025

Manteca City Council
April 15, 2025