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From: Lauren.Bisnett@WATER.CA.GOV
Subject: DWR Releases Draft Prioritization Under SGMA
Date: May 18, 2018 at 1:45:19 PM PDT

DWR Releases Draft Prioritization of Groundwater Basins Under Sustainable Groundwater Management Act

The DWR Sustainable Groundwater Management Program today released a draft prioritization of groundwater basins as required by the Sustainable Groundwater Management Act (SGMA). The 2018 SGMA Basin Prioritization is scheduled to be finalized by fall 2018 after a 60 day public comment period that starts today and runs through July 18, 2018.

Basins throughout the state are ranked high-, medium-, low-, or very low-priority. Basins ranking high- or medium-priority are subject to SGMA. Of the 517 groundwater basins statewide, the newly released draft prioritization identifies 109 basins as high- and medium-priority, which includes 14 basins newly ranked as high- or medium-priority. Additionally, 38 basins previously ranked as high or medium-priority are now ranked as low- or very-low priority and are no longer subject to SGMA. Draft prioritization results can be viewed using DWR’s newly developed visual application tool, the 2018 Prioritization Dashboard.

DWR will hold a public webinar May 30 to present the draft results, followed by statewide public meetings at the end of June. DWR will be taking public comments on the draft results, including additional data or information that is consistent with statewide datasets identified in the Basin Prioritization Process and Results Document. For more information, please refer to the 2018 SGMA Basin Prioritization Frequently Asked Questions.

When the 2018 SGMA Basin Prioritization is made final, the basins newly subject to SGMA must form Groundwater Sustainability Agencies (GSAs) within two years and develop Groundwater Sustainability Plans (GSPs) within five years, or submit an Alternative Plan within two years. DWR provides a wide-variety of resources and services to support local agencies and GSAs in implementing SGMA.

Low- or very low-priority basins are not subject to SGMA, but are encouraged to form GSAs and GSPs, update existing groundwater management plans, and coordinate with adjacent basins to develop a new groundwater management plan.

For more information or to submit a comment, please visit:State Groundwater Management Prioritization Program

11/2/16

Public comment is open on the County's recent study of groundwater (gw) in the Napa Valley, in order to comply with the California State Law: Sustainable Groundwater Management Act, SGMA.

A workshop is being held tomorrow, November 3rd, from 3-6 at 2121 Imola, Napa County Office of Education.

Public comment (3 minutes) is allowed after their consultant presents the study.

You can review the Draft Basin analysis (DBA)/Napa Valley Groundwater Sustainability documents here.

There consultant is Luhdorff and Scalmanini (LS) who say gw in the Napa Valley aquifer is stable and does not need gw management.

Their document is lacking in these areas (to mention a few):

• False baseline of gw surface elevation: historically gw was at the surface (0 mean sea level) level in Calistoga-now gw is 10 feet below the surface in Calistoga and there is on-going dewatering of the Napa River from Calistoga to Hardman lane.
  
• misleading information about groundwater quality-LS admit that gw quality is poor in many areas of the County due to boron, arsenic, nitrogen and heavy metals but dismisses this by calling it "normal.
  
• misleading information about the root zone modeling outcomes-LS discuss root zone modeling on the valley floor but ignore the upper/wild watershed in their water budget-this allows them to not model the impacts of deforestation on gw recharge
  
• ignores Public Trust values and resources
  
• fails to discuss or define " undesirable results" required by SGMA such as: declining gw quality, wells going dry, fish kills, de-watering of the Napa River and streams, salt water intrusion, land subsidence; all of which are occurring now, on-going and re-occurring since January 2015. If "undesirable results" are present in the Napa River watershed, the County is required to do a Groundwater Sustainable Plan, GSP, by 2020 and a Groundwater Sustainable Agency, GSA, by June 2017.
  
• mis-characterizes the water budget elements-discusses the vines production at 20,000 acres and holding and ignores the recharge area in the hills where deforestation and vines are being planted by thousands of acres each year
  
• fails to account for the major use of groundwater at 60% during drought-causing de-watering of streams

Because of this, Napa County shouldn't have this Alternative monitoring plan but instead get going on a Groundwater Sustainable Plan, GSP.

Background on why Napa County has chosen to do a DBA, (just continued monitoring) instead of Groundwater Sustainable Plan (includes a plan for sustainable extraction of gw): The Sustainable Groundwater Management Act (SGMA), historic legislation enacted by Governor Brown in September 2014, provided a new structure for sustainable management of California's groundwater basins. On January 1, 2015 the California Department of Water Resources (DWR) began implementing the Act, including the development of new regulations to guide local groundwater sustainability efforts. SGMA established a sustainability goal for groundwater basins throughout the state, prioritized basins, established a timeline for implementation, and provided for new Groundwater Sustainability Agencies (GSA). It also required the development of Groundwater Sustainability Plans (GSPs), or Alternatives that are equivalent to them, to ensure that basins are operated within their sustainable yield.

In basins that have ongoing successful groundwater management programs, a local agency may elect to submit a Basin Analysis Report Alternative that demonstrates that the groundwater basin is being sustainably managed. With direction from the Board of Supervisors on March 3, 2015, Napa County began work to implement SGMA through development of a Basin Analysis Report for the Napa Valley Groundwater Subbasin. Napa County was well suited to meet the requirements for this Alternative due to its groundwater sustainability program, which includes: an ongoing and evolving groundwater monitoring network and program, annual groundwater conditions reporting, an Updated Hydrogeologic Conceptualization and Characterization of Conditions Report (2013), development of new groundwater/surface water monitoring facilities along the Napa River, and a long-term public education and outreach program through the Watershed Information & Conservation Council of Napa County.

You should come tomorrow and listen to the presentation and be prepared to say something about the process and lack of correct information being presented to the both the WICC Board tomorrow and subsequently the BOS on Tuesday December 13, 2016 at a Special Meeting.

Keep in mind that if the BOS approve this Alternative to be submitted to the Department of Water Resources by January 1, 2017, and the DWR accepts this bogus Alternative this denies us groundwater management for an undetermined amount of time.

Our aquifers deserve our voice if we want sustainable gw for future generations. The time to act is now.

Chris Malan

"Good morning David,

I need to fully understand why the County has painted itself into a corner by going "all-in" for the alternate plan. Initially, what individual or group came to that determination? Was it Patrick Lowe's regime, WIIC recommendation, BOS? I would hope it wasn't from the consultant group L&S. Our year long study related to enhanced protections for our watershed [the subverted Oak Woodland Initiative] uncovered strong needs for preservation of our oak woodlands and riparian corridors. This is about the future of not just supply, but equally important the quality of that supply. How can we plan for our children's future without ensuring quantity and quality?

I know you would agree that our water resource is THE most important resource needed to sustain life. Why are we gambling with this absolutely-necessary resource for life itself? What was the reasoning for selecting the alternate plan? It would be heartbreaking to think it was about $$. We need and will continue to demand an ongoing process like a sustainable groundwater plan. I simply am dumbfounded that we're trying to cut corners here! Dumbfounded!

Lastly, L&S appear to have cherry picked data and modeling to support the alternate plan, which is disturbing enough. But more scary is that their future assumptions are based on current conditions: like no increased development. What a "crock." We have the demand for 5,000 more acres of conversion from forest to vineyard in the pipeline right now. Many of those 113 wells are recently on line. We are gambling with our most important resource. This is outrageous and very troubling. I've admired your intellect and participation for several years now. Why do you not see the contradiction here? Those of us who are only in this fight because of the need for truth, justice and the dignity of life will continue to educate our fellow citizens that we are being sold ' a bill of goods" leading to the ultimate destruction of our Valley. We will continue until our last breaths to awaken our residents to these corporate blind ambitions.

Mike Hackett"

Napa County Planning Commission:

How can your conscience allow any more winery/vineyard/water-use expansion in the Simmons Canyon Creek Watershed?

The Emperor has no clothes. Simmons Canyon Creek watershed is dead. No matter how much “reassurance” from “experts” of abundant water when seeking permits or “blessing” of permit violations, the water just ain’t here, no mo’. Our wells are dry. Water trucks roll constantly up and down Pickett and Rosedale (4 trucks daily just for Treasury!). Have for years. Pickett Road Wine Company’s own wells evidence the decline. All the flowery words to obfuscate and confuse can’t “water down” the reality - water’s gone. Simmons Creek has been murdered, RIP - September 2020. Our well, RIP - September 2020. Neighbor’s well, RIP - September 2020.

A week before Glass fire, for the very first time in the 100 years that we have sustainably farmed the Simmons’ watershed, Simmons stopped flowing. Stopped moving. Dead. Disconnected little pools of water, filled with algae, scummy, stinky. Dead fish? Thank you Napa County officials for dewatering Simmons Creek and harming every living creature within its watershed. And then, our well went dry.

My creek - Simmons Canyon Creek, an incredibly lush blueline stream; yes, “teeming” with fish, wildlife, trees, flowers, the Tofanelli kids and WATER! State docs refer to Simmons as “Intermittent” because, in summer months, it historically undergrounds before it gets to the Silverado Trail, then resurfaces several hundred feet to the west, along the historic Tucker property, then continues to the Napa River. Desk jocky-techs would never know that - have to walk the creek. Until last September, it flowed EVERY day, for the last 100 years, all along our property and the Calistoga Waste Water Ponds to the Napa River. Not “intermittent”.

We lived in the creek all summer after working in the vineyard. We swam, rafted, tubed, fished, splashed - every warm afternoon. Then Simmons would flood in winter, filling the basement. One year, mom tied my brother’s raft to the back steps as the creek kept rising - she was sure we’d have to float out. My family has lived sustainably in the Simmons watershed for almost 100 years. Our creek was the sole source of domestic water for our property until we drilled the well in 1954. Then the creek kept watering the gardens and orchards.

But NOT the vines. Grape vines do not require irrigation. Water equals tonnage, tonnage equals gallons, gallons equal money. Real old-vine, dry-farmed wines are the most intense and the most sought after - and naturally limited. But there’s an even bigger market for millions more gallons - watered-down or not. Little known is the fact that most of the wine produced in Napa County, using our water and other resources, is not made from grapes grown here. Per 2015 crush data, less than 1/3 of all grapes crushed here are grown here. Almost 70% (68.5%) of all grapes crushed in Napa County were trucked in - so they can print a prestigious Napa address on the label, which brings way more consumer cash.

In 1968, the Board of Supervisors approved then-controversial regulation to create the nation’s first, and now much-revered (in name), Agricultural Preserve. Their intent was to save the land from being paved over at a time when so much prime ag land was being lost to shopping malls and subdivisions and Napa Valley was just starting to be carved up. At that time, our number one ag product was CATTLE! Animals and animal feed were worth four (4) Times (400%) what Napa grapes were worth. Four (4) times!

Their intent was not to create a tourist industry that would become so successful for some that it now threatens that which we originally sought to preserve. They sought, instead, to secure the public trust by saving our rich soils for future food production. Unintended consequences.
As former Supervisor Mark Luce pointed out: “I don’t think we protect agriculture because it’s an economic engine. We protect agriculture because it’s a principle that we protect agriculture and I think that’s what we did in 1968. I don’t think it was that the Board said ‘we’re going to get rich by protecting agriculture’. It was just saying that agriculture is important to feeding people and supporting the world.”

So how did we get here? and why? We used to elect/appoint officials who understood their fiduciary duty to the public trust - brave enough to fight for then-controversial protections. Now forgotten, the battles were legendary.

But how did we get here, now? Money. Greed. We now elect officials who are beholden to the wine/tourist industry. The industry has even managed to change the legal definition of “agriculture” in Napa County to now include sales (parties! events! = highest and best use of the land!). No amount of evidence of aquifer overdraft presented by the public, and/or experts hired by the public, is ever deemed credible by the county, which advocates solely for the project applicant. So all wineries (except one!) and vineyards are approved. No matter how remote, steep, dangerous or dry (Mountain Peak?). And no matter how much water is trucked in. (Or waste hauled out, but that’s a story for another day.)

Napa County applies a groundwater formula that basically allocates 1 acre-foot of water annually per 1 acre of valley-floor land (whether water is really there, or not). So, a 12-acre winery is assumed to be able to draw 12 acre-feet of water annually without impact. What grand fiction! Ask winery owner Kirk Venge. Built his winery in 2010, (permitted per the county’s “1 acre = 1 acre-foot” formula), he had to immediately truck water in. Then, despite all the public testimony about area dry wells and neighbors forced to truck water as well as the fact that the former owners (an older couple with no lawns or pools) needed 4 wells, he proceeded to sue the widowed former owner, apparently for not disclosing water problems!

Where does the water come from? Truck after truck, grinding pavement down, clogging roads, hauling water to remote locations that should never be “farmed”. Most of it from city hydrants that really pipe it from the Sacramento Delta via that good ol’ fixer, the North Bay Aquaduct! Treasury alone hauls 4 trucks almost every day into Pickett/Rosedale. Neighbors curse the trucks up and down, up and down, all day, eating pavement - many apparently going right into the subject winery.

So, while city residents with no other option are rationed, vineyard managers just load up at city hydrants and truck all that water (that the residents are prohibited from using - rationing, right?) out to irrigated vineyards planted on dry land. As our well is now dry, we’re also forced to buy Napa city water - for as long as Napa city will allow. When will Napa shut down the vineyard hydrants to protect their residents? I’ve attended meetings where this is seriously discussed.

Ever since the Ag Preserve was created forces have determined to defeat its intent. And they have succeeded. Napa County’s “Agricultural Preserve” has nothing to do with preserving real, sustainable agriculture - but it’s a great marketing slogan. Monuments to it are all over the county. And Napa County officials, over the years, have knowingly and willingly violated their fiduciary duty to the public trust by allowing continuous overdraft of the ground water aquifer for private benefit. Without water we cannot grow food.

“Under the Public Trust Doctrine, the trust property is the environment. The government is the trustee of these natural resources and must manage them subject to fiduciary duties, for the benefit of both present and future generations, who are the beneficiaries of the public trust.”1

1. Quirke, Douglas, The Public Trust Doctrine: A Primer (University of Oregon School of Law Environmental and Natural Resources Law Center, 2016), 2.

Norma J. Tofanelli
Calistoga
4th-generation Napa County farmer
Napa County Farm Bureau President 2013-16

PS: Common sense demands NO VISITATION during PSPS or RED FLAG days...

Addedum:
I have been “witnessing” and warning for 40 years of the dewatering of our watershed. I incorporate by reference files which are too large for email: all water documentation that I have submitted to the County of Napa at various public hearings, from 1984 forward, on the following winery use permits and issues: Clos Pegase, Girard, Pavitt, Venge, Fisher, Paoletti, Canard; water data submitted to the 1990 WDO FEIR by Napa County Environmental Engineer Jill Pahl; 1990 WDO FEIR, Dunaweal Lane area well logs/legend, 2016 Ag definition hearings.

And when did Simons Creek fall ill? When Cab was first planted along Simmons/Pickett and then expanded into Eisele Vineyard in 1969. That’s when the creek first started to suffer. It dramatically declined through ’70’s - ’80’s. More wineries and irrigated vineyards reduced it to a mere trickle - finally stopped September 2020. Revived a bit with rains over winter. Trickling now - but in a few days it will die again.

During those years, dry farming was forced to change. We never before had to irrigate new plantings. Ground water level was so high, the roots easily extended without initial watering. Now, we have to water (by manually-placed drip or bucket) for 2 years or the little cuttings die. Very obvious evidence of withdrawal of aquifer. Very expensive, labor intensive; replant costs may be prohibitive for many small farmers.

And the ultimate pain for a 100-year Napa County sustainable dry-farmer? Despite all our efforts and warnings, we have no water. We are forced to bring in storage tanks and truck water from Napa City hydrants. Not to mention adding necessary water filtration systems - never needed before. Very costly in ways not often considered.

Tofanelli well / drilled 1954 / 120’ deep Static level: 2/14 = 12’
Static level: 9/20 = 120’
Static level: 2/21 = 100’
sited about 50’ from Simmons’ bank


Only he can understand what a farm is, what a country is, who shall have sacrificed part of himself to his farm or country, fought to save it, struggled to make it beautiful. Only then will the love of farm or country fill his heart.
ANTOINE DE SAINT-EXUPERY, Flight to Arras

11/2/16

Public comment is open on the County's recent study of groundwater (gw) in the Napa Valley, in order to comply with the California State Law: Sustainable Groundwater Management Act, SGMA.

A workshop is being held tomorrow, November 3rd, from 3-6 at 2121 Imola, Napa County Office of Education.

Public comment (3 minutes) is allowed after their consultant presents the study.

You can review the Draft Basin analysis (DBA)/Napa Valley Groundwater Sustainability documents here.

There consultant is Luhdorff and Scallimini (LS) who say gw in the Napa Valley aquifer is stable and does not need gw management.

Their document is lacking in these areas (to mention a few):

• False baseline of gw surface elevation: historically gw was at the surface (0 mean sea level) level in Calistoga-now gw is 10 feet below the surface in Calistoga and there is on-going dewatering of the Napa River from Calistoga to Hardman lane.
  
• misleading information about groundwater quality-LS admit that gw quality is poor in many areas of the County due to boron, arsenic, nitrogen and heavy metals but dismisses this by calling it ‘normal’.
  
• misleading information about the root zone modeling outcomes-LS discuss root zone modeling on the valley floor but ignore the upper/wild watershed in their water budget-this allows them to not model the impacts of deforestation on gw recharge
  
• ignores Public Trust values and resources
  
• fails to discuss or define ‘ undesirable results’ required by SGMA such as: declining gw quality, wells going dry, fish kills, dewatering of the Napa River and streams, salt water intrusion, land subsidence; all of which are occurring now, on-going and re-occuring since January 2015. If ‘undesirable results’ are present in the Napa River watershed, the County is required to do a Groundwater Sustainable Plan, GSP, by 2020 and a Groundwater Sustainable Agency, GSA, by June 2017.
  
• mischaracterizes the water budget elements-discusses the vines production at 20,000 acres and holding and ignores the recharge area in the hills where deforestation and vines are being planted by thousands of acres each year
  
• fails to account for the major use of groundwater at 60% during drought-causing dewatering of streams

Because of this, Napa County shouldn’t have this Alternative monitoring plan but instead get going on a Groundwater Sustainable Plan, GSP.

Background on why Napa County has chosen to do a DBA, (just continued monitoring) instead of Groundwater Sustainable Plan (includes a plan for sustainable extraction of gw): The Sustainable Groundwater Management Act (SGMA), historic legislation enacted by Governor Brown in September 2014, provided a new structure for sustainable management of California’s groundwater basins. On January 1, 2015 the California Department of Water Resources (DWR) began implementing the Act, including the development of new regulations to guide local groundwater sustainability efforts. SGMA established a sustainability goal for groundwater basins throughout the state, prioritized basins, established a timeline for implementation, and provided for new Groundwater Sustainability Agencies (GSA). It also required the development of Groundwater Sustainability Plans (GSPs), or Alternatives that are equivalent to them, to ensure that basins are operated within their sustainable yield.

In basins that have ongoing successful groundwater management programs, a local agency may elect to submit a Basin Analysis Report Alternative that demonstrates that the groundwater basin is being sustainably managed. With direction from the Board of Supervisors on March 3, 2015, Napa County began work to implement SGMA through development of a Basin Analysis Report for the Napa Valley Groundwater Subbasin. Napa County was well suited to meet the requirements for this Alternative due to its groundwater sustainability program, which includes: an ongoing and evolving groundwater monitoring network and program, annual groundwater conditions reporting, an Updated Hydrogeologic Conceptualization and Characterization of Conditions Report (2013), development of new groundwater/surface water monitoring facilities along the Napa River, and a long-term public education and outreach program through the Watershed Information & Conservation Council of Napa County.

You should come tomorrow and listen to the presentation and be prepared to say something about the process and lack of correct information being presented to the both the WICC Board tomorrow and subsequently the BOS on Tuesday December 13, 2016 at a Special Meeting.

Keep in mind that if the BOS approve this Alternative to be submitted to the Department of Water Resources by January 1, 2017, and the DWR accepts this bogus Alternative this denies us groundwater management for an undetermined amount of time.

Our aquifers deserve our voice if we want sustainable gw for future generations. The time to act is now.

Chris Malan

"Good morning David,

I need to fully understand why the County has painted itself into a corner by going "all-in" for the alternate plan. Initially, what individual or group came to that determination? Was it Patrick Lowe's regime, WIIC recommendation, BOS? I would hope it wasn't from the consultant group L&S. Our year long study related to enhanced protections for our watershed [the subverted Oak Woodland Initiative] uncovered strong needs for preservation of our oak woodlands and riparian corridors. This is about the future of not just supply, but equally important the quality of that supply. How can we plan for our children's future without ensuring quantity and quality?

I know you would agree that our water resource is THE most important resource needed to sustain life. Why are we gambling with this absolutely-necessary resource for life itself? What was the reasoning for selecting the alternate plan? It would be heartbreaking to think it was about $$. We need and will continue to demand an ongoing process like a sustainable groundwater plan. I simply am dumbfounded that we're trying to cut corners here! Dumbfounded!

Lastly, L&S appear to have cherry picked data and modeling to support the alternate plan, which is disturbing enough. But more scary is that their future assumptions are based on current conditions: like no increased development. What a "crock." We have the demand for 5,000 more acres of conversion from forest to vineyard in the pipeline right now. Many of those 113 wells are recently on line. We are gambling with our most important resource. This is outrageous and very troubling. I've admired your intellect and participation for several years now. Why do you not see the contradiction here? Those of us who are only in this fight because of the need for truth, justice and the dignity of life will continue to educate our fellow citizens that we are being sold ' a bill of goods" leading to the ultimate destruction of our Valley. We will continue until our last breaths to awaken our residents to these corporate blind ambitions.

Mike Hackett"

Water Availability Analysis (WAA)

Water Availability Analysis (WAA) 2014-11-05 6 30 pm 8 30 pm Napa County Library, 580 Coombs Street Napa, CA 94559 There will be a Public Workshop on proposed changes to Napa County’s Water Availability Analysis (WAA) at the Napa County Library on Wednesday, November 5th at 6:30pm.