SodaCanyonRoad | Napa Groundwater Sustainability Plan
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Napa Groundwater Sustainability Plan
Bill Hocker | Sep 6, 2022 on: Watershed Issues


Click for 2021 Annual Sustainability Report

Update 9/6/22
NV2050 9/6/22: The Napa County GSA Appoints:"Technical Advisors" or "Industry Lobbyists"?

Update 5/9/22
NV2050: "My well is running dry"

Napa Vision 2050 unearths the County's current magical thinking and buried data in their Groundwater Sustainability Plan.

Update 4/22/22
Dan Mufson sends this article that parallels Napa County's own sinking groundwater situation.

NVR 4/22/22: Can the Paso Robles wine industry continue to thrive as groundwater levels fall?

Update 3/23/22
NVR 3/24/22: Napa County raises red flags on groundwater

The 2021 Groundwater Sustainability Report was presented by PBES to the Supervisors at their 3/22/22 meeting (Staff agenda letter is here). From the Agenda Letter:

"As a result of the current prolonged and increasing drought conditions, and as documented in the GSP Annual Report attached, the Minimum Thresholds for the following Sustainability Indicators have been exceeded:
1. Chronic groundwater decline;
2. Reduction in groundwater storage;
3. Depletion of interconnected surface water;
4. Land subsidence; "

Until now previous studies have indicated that the amount of groundwater available for the water needs of Napa county businesses and residents has been just sufficient for our needs. The county has always patted itself on its back over its conservation policies intended to insure the availability of water for its agricultural industry (while the central valley runs dry and sinks). This report comes as a surprise to all -- except, of course, the county's environmental activist community that has been predicting it for years. And 2022, as we all recognize, is not going to improve the outlook. This is probably a first indication that not only will current water practices have to be reviewed and perhaps curtailed, but that all future building and vineyard development in the county will now be evaluated on a realistic evaluation of their impact on an already exceeded supply of groundwater.

For those of us in the watersheds who have seen wells or springs go dry in the last few years, this study leaves a huge hole in the analysis. It only looks at the water conditions in the "Napa Valley Subbasin", ie the valley floor.

From the report:
    "Conditions that may lead to an UR [undesirable result, ie not enough water] due to reductions of groundwater storage include increased groundwater extraction without offsetting increases in groundwater recharge, which could result from:
    • Prolonged drought conditions, such as drought conditions exceeding the severity and duration of historical droughts, and
    • Reduced surface water supply availability due to physical, legal, or other constraints."

These conclusions are based on an agricultural base in the valley which has actually declined in acreage since 1987. Hence no mention of additional irrigated acreage, the largest consumer of groundwater, as contributing to the "UR".

For some reason that I still don't understand, the analysis of groundwater in the subbasin doesn't seem to consider changes in the mountainous watersheds that supply water to the basin. And the amount of vineyard acreage added in the watersheds above the valley in that period is substantial (for example rector watershed). Somehow an assumption is made that the vast amount of groundwater extracted for watershed vineyards is unrelated to the amount of groundwater that eventually reaches the subbasin, and is not indicated as contributing to the "UR". This is a perplexing conclusion. The entirety of groundwater sucking vineyards created in Napa County the last 20 years has been in areas not defined by the Subbasin. And those areas are excluded form the Napa County Groundwater Sustainability Plan (including the foreground vineyard on the GSP Report cover). A great mystery.

[3/31/22: Amber Manfree, our resident scientist and member of the GSP committee, has attempted to dispel the mystery. Projections of water use in the GSP Report are made using the Napa Valley Hydrologic Model, a complex mathematical algorithm that takes into account the many variables that affect and will affect the amount of groundwater under the Napa Valley. The amount of water pumped from watershed aquifers is actually a part of that calculation. And the conclusion drawn by varying watershed vineyard acreage in the model is that watershed pumping has very little impact; the overwhelming amount of water that replenishes the subbasin is surface water that flows from the watersheds in streams and dam spillways.

As I have noted elsewhere, the Rector watershed is now at 21% vineyard coverage, while the county's other watersheds are at 8% coverage. It would be somewhat comforting to have the model calculate a 21% coverage for the entire Napa river watershed to verify that watershed pumping will remain insignificant.]

Update 1/14/22
NVR 1/13/22: Napa County approves groundwater plan - but there's more to come

Update 12/11/21
Letters of concern about the Groundwater Sustainability Plan may be submitted until 12/14/21 at 5:00pm. Letters my be submitted to David.Morrison@countyofnapa.org
NV2050 exhortation to submit letters

NVR 12/8/21: Napa County's groundwater protection plan draws mixed reviews
NVR 12/3/21: Napa County unveils groundwater strategy

On 12/7/21 the County BOS, in their capacity as the Napa Groundwater Sustainability Agency (GSA), met to consider transmittal of the Groundwater Sustainability Plan (GSP) to the CA Dept of Water Resources, as-is or with edits. (See Item 12A of the meeting agenda here)

The draft sections of the GSP are here.

Four members of the Groundwater Sustainability Plan Advisory Committee (GSPAC) are not in support of recommending the current draft of the GSP to the Agency for review because it fails to adequately protect environmental users of groundwater from adverse impacts. Their letter is here.

Also:
NV2050 Eyes on Napa 12/3/21: Voices From the Committee (Extensive interviews with committee members on their takeaways from the process).
Eve Kahn for NV2050 LTE, 12/1/21: Napa’s water: a dangerously flawed plan

Update 11/24/21
Gary Margadant has issued a public rebuke to the Groundwater Sustainability Plan Advisory Committee over member, and Napa City Water Manager, Joy Eldridge's sidelining in committee meetings.
Gary Margadant LTE 11/23/21: Why treat a water manager so poorly?
GSPAC agenda and video page

Update 10/13/21
Water Audit California has uploaded videos of the first two public meetings presented by the County on the Draft Groundwater Sustainability Plan. Links to the videos are here.

The County has added agendas, PowerPoints, and participant Q&A's from the presentations on their meeting page here.

Pam Smithers LTE 10/13/21: Some steps to protect our groundwater

Update 9/20/21
NVR 9/18/21: Napa County's groundwater plans moving to spotlight
NVR 9/20/21: Drought takes a toll on Napa County wildlife
Dan Mufson LTE 9/28/21: Our Spine is Broken
Chris Malan LTE9/2/21: The Drying Up of the Napa RIver

Two in-person meetings and one online meeting are being held by the County to present their Draft Groundwater Sustainability Plan on 9/22/21 at Napa Valley College, 9/29/21 at the NVC up-valley campus in St Helena and 10/6/21 online. Registration, time and location information is here: https://www.countyofnapa.org/3235/Upcoming-Events

Update 2/20/21
Groundwater Sustainability Plan Advisory Committee meetings Agendas, Documents, Videos

Update 9/15/20
NVR 9/15/20: Citizens group begins deep dive in Napa Valley groundwater issues

9/10/20
2020 County Groundwater Sustainability Plan Documents

Update 6/11/20
The County will have a Water Availability Analysis workshop with the Planning Commission on 6/17/20 (subsequently cancelled). Several documents will form the background for the discussion:

Draft markup of the 2015 WAA Guidance Document
Executative Summary of the Napa County Groundwater Sustainability Annual Report fo 2019
Comprehensive Timeline of County WAA activities since 1963<

Update 1/9/20
NVR 1/9/20: New Napa County groundwater agency hears from critics at its first meeting
NVR 12/29/19: Napa County supervisors to govern groundwater agency
NVR 11/22/19: State tells Napa County to form agency to monitor Napa Valley groundwater
NV2050 12/21/19: Sustainable Groundwater Management Agency (SGMA)

Update 7/24/19
NVR 7/19/19: State dissatisfied with Napa wine country groundwater plan
Mike Hackett LTE 7/24/19: Take real action on water and development

Update 3/20/19
NVR 3/20/19: Report says Napa County's 2018 groundwater levels stable

2018 Napa County Groundwater Sustainability Annual Report
Report Summary

Staff will be presenting the Report to the Supervisors on Mar 19, 2019. The Agenda letter is here

Update 5/21/18

Click image to open Basin widget. Click on Napa basin in widget for basin data
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.


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


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.

Update 4/25/17
NVR 2/25/17: Napa County says groundwater picture continues to be good

Update 2/15/17
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).

State Links:
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

County Links:
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

Individual Responses:
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

11/13/16
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].

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


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.

Mike Hackett"