Bill Hocker | May 21, 2018
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NVR 5/24/18: State proposes change in monitoring status for Napa County's groundwater
Chris Malan has passed along the email below from the State Department of Water Resources which indicates that the Napa Subbasin has been reclassified in a draft document from a "medium-" to "high-" priority basin. It is unclear how this change would affect Napa's Groundwater Sustainability Alternative but does suggest that the condition of the Napa Subbasin may be of greater concern than the county has indicated. A public comment period on the Draft runs through July 18th, 2018.
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:https://water.ca.gov/Programs/Groundwater-Management/Basin-Prioritization
Dan Mufson of NapaVision2050 has sent a copy of his 2/15/17 letter in response to the County's Sustainable Groundwater Management alternative critical of the alternative's lack of consideration of an increasingly dryer climate future.
NVR 2/25/17: Napa County says groundwater picture continues to be good
This is a summary of documents and posts on Napa County's sustainable groundwater management alternative plan, titled Napa Valley Groundwater Sustainability - A Basin Analysis Report for the Napa Valley Subbasin, in response to the State's Sustainable Groundwater Management Act (SGMA).
Sustainable Groundwater Management Act (SGMA)
Sustainable Groundwater Alternative Plan description
List and Map of all water district SGM Alternatives with comments
Comments specifically on the Napa County Plan
12/13/16 Staff Presentation of supporting documents for the Napa Valley Groundwater Sustainability - A Basin Analysis Report for the Napa Valley Subbasin to the California Dept of Water Resources (DWR), Item 9A on the Board Agenda.
The County's Groundwater Basin Analysis page
The Nov 3rd WICC workshop and draft report
Napa Grand Jury 2014-15 Report on groundwater
Donoviel LTE 2/26/17: Concerns over water plan
Gary Margadant: What is Happening to Our Most Precious and Irreplaceable Resource: Our Water
Letter sent to the BOS on Dec 19th 2016
Chris Malan, Mike Hackett: Napa's Sustainable Groundwater alternative
Dan Mufson: got Water? Will you have water?
Responses to the Draft Napa Valley Basin Analysis Report
Chris Malan has sent this informative email concerning the WICC workshop that was held on Nov 3rd, with the resulting workshop report to be presented to he BOS on Dec 13th 2016 [now Dec 20th].
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.
The WICC Nov 3rd workshop agenda with supporting documents are here.
The county's page on groundwater sustainability is here
DIssenting voices to the County's proposed alternative to SMGA requirements by Gary Margadant and Gordon Evans among others are summarized in this response to comments, one of the documents in the Nov. 3rd workshop packet.
In an email to WICC Board Member David Graves after the Nov 3rd workshop, Mike Hackett of Angwin writes:
"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.