ALERT: Groundwater Sustainability Act (GSA) sample letters and concerns

If you want to have a say or in the minimum be represented for water use in your county for generations to come, be aware that all county’s in the state are organizing the mandated GSA panels (June 30, 2017 deadline) that will over see water use into the far future, all water extractions, fees, projects and more.  This panel will even have powers of imminent domain, ability to raise fees, collect and mandate capital projects among other enormous powers. (See previous article for more). All water users will be affected no matter how small. Let’s make science the overriding factor in decision making process and not turn this into a political football for the wealthy special interests.

Please send to your supervisors and city councils an email so they know the public is watching and it is NOT politics as usual.

Copy and paste or make your own comments from the letter below.

Sonoma County Supervisors addresses: Susan.Gorin@sonoma-county.org      David.Rabbitt@sonoma-county.org   Shirlee.Zane@sonoma-county.org   James.Gore@sonoma-county.org   Efren.Carrillo@sonoma-county.org

NAPA County Supervisors:

logo high piexel 2SAMPLE LETTER

Email to: Board & Council Members of all GSA Eligible Organizations in Sonoma County

Sonoma County soon will be forming Groundwater Sustainability Agencies (GSAs) as specified by the Sustainable Groundwater Management Act of 2015 (SGMA). SCWC members have grave concerns about the success of the GSAs if they are organized without consideration of local water uses that vary significantly from those in other California counties.

SGMA states that GSAs are to be formed by one or a combination of several local agencies, but in Sonoma County the major local agencies represent populations that rely almost entirely on surface water drawn from the Russian River. Those who rely on groundwater, who know the most about it and are the most concerned about sustainability, especially small mutual water companies that draw all their water from wells, may have a minor or no seat at the table. This situation may be unique in the State of California, requiring a different type of GSA to ensure broad representation of groundwater users.

The County’s local agencies include County government, the surface water-producing and water-distributing Sonoma County Water Agency (SCWA), which sells that water to other jurisdictions, representing most of the County’s towns and cities. The following facts explain the situation:

• The Sonoma County Board of Supervisors is also the SCWA Board of Directors.

• SCWA’s contractors include the County’s most populous urban areas: Santa Rosa, Windsor, Cotati, Rohnert Park — all in the Santa Rosa Plain groundwater basin, and Petaluma, in the Petaluma Valley groundwater basin.

• The City of Sonoma, and the Valley of the Moon Water District in the Sonoma Valley groundwater basin also receive Russian River water deliveries.

Virtually all of Sonoma County’s mutual decision-making about water supplies, wastewater treatment, and related issues takes place in councils consisting of representatives from these agencies and jurisdictions, which also include representatives from another county, since SCWA sells Russian River water to the North Marin and Marin Municipal Water Districts.

In Sonoma County the only urban areas that do not substantially rely on surface water supplies are Sebastopol, Healdsburg and the unincorporated towns of Graton, Penngrove, Bodega, and

Bodega Bay. These towns and cities are not represented on the councils described above.1

1Following the 1970s drought, SCWA constructed emergency groundwater wells in the Laguna de Santa Rosa. For a number of years SCWA added pumped groundwater to the pipeline, but it still carried predominantly Russian River water.

Excepting Sebastopol, none of the groundwater-dependent towns and cities are located in identified scarcity areas, requiring formation of a GSA.

The GSA board will be a powerful force in Sonoma County communities. Decision makers need input from agricultural and domestic well owners, mutual water systems dependent on wells, water-focused environmental groups, and Sonoma Resource Conservation District (RCD) if policies are to be cost-effective, science based, inclusive of all impacts, efficient and have buy-in from the large percentage of ground-water users in our groundwater basins.

SCWC members submit that Sonoma County’s unique relationship to surface and groundwater supplies requires the GSAs to be formed with great care. SGMA does allow for “Alternative Plans,” which in Sonoma County can mean inclusion of groundwater users and technical advisors with pertinent expertise. We believe that this will lead to decisions and actions based on facts and full scientific assessments. In addition, we feel that growing climate uncertainty requires technical expertise for guiding groundwater policy and decision-making.

We are concerned that a GSA consisting entirely of elected officials or political appointees will:

• Have limited knowledge and experience of water supply other than the County’s wholesale and retail surface water supply (primarily the Russian River);

• Have no knowledge, or very limited knowledge of hydrology, geology, land-use planning and other fields of great importance for establishing groundwater sustainability programs;

• Represent jurisdictions with priorities based on local interests, such as maintaining surface water allotments;

• Be forced to rely unduly on staff, which has yet to be assigned, defined, or funded. Local urban staffs may lack technical expertise in climate, water, and sustainability fields;

• Leave out direct stakeholders and well users who depend on groundwater sustainability, and whose involvement is necessary to fulfill SGMA goals.

Potential Sonoma County GSA Composition:

GSAs might include elected officials from the surface-water dependent jurisdictions discussed in the foregoing, with the addition of appointed stakeholders, including Resource Conservation District personnel; representatives of rural and agricultural well owners; mutual water system operators; environmental group representatives, others (“at large”); and technical experts. Staff might be drawn from SCWA, local jurisdictions, Utility Districts, DWR, or new hires.

A Conceptual GSA Formulation

In our view, a GSA for each Sonoma County basin should consist of 9 to 11 members, comprising:

A. Elected officials representing as many as 5 Sonoma County authorities, including SCWA and at least one groundwater-dependent jurisdiction. These jurisdictional representatives, other than SCWA should rotate every 3-5 years to keep them all involved.

B. Appointed stakeholders, representing those directly impacted by GSA decisions and able to affect groundwater sustainability, including: Agricultural well owner(s) — potentially Sonoma RCD, others;

Rural domestic well owners; Well-dependent mutual water systems; Water-focused environmental organizations (local/national); and Independent technical experts.

Initial candidates for such appointments should be selected from current members of the collaborative Sonoma Valley and Santa Rosa Plain Basin Advisory Panels, organized under AB 3030.

Technical Advisory Committee:

SGMA allows a GSA to appoint an advisory committee to provide technical expertise. Members of such a Technical Advisory Committee (TAC) could be drawn from:

SCWA staff or utility departments with specialization in groundwater related science

Basin Advisory Panel members, with many years experience of the collaborative process;

Independent consultants;

Academic/scientific experts;

Representatives from jurisdictions reliant on wells;

Ag well owners;

Domestic well owners;

Mutual water company representatives;

Environmental organization representatives.

Scientific experts should represent fields such as:

Hydrology, including an expert on hydrologic modeling;

Geology, including expertise on sedimentary and bedrock geology;

Wetlands biology and fisheries biology;

Land use planning.

Our experience is that advisory groups appointed by elected officials have little power to guide decision making, however. If experts serve at the pleasure of an appointing board, their effectiveness may be severely limited. We therefore advise that the GSA powers relative to the advisory board should be defined by governing rules, such as:

Requirement for a supermajority GSA vote to reject a TAC recommendation, and of

Findings in support of GSA votes or actions on TAC recommendations, whether negative or positive, in writing, which they must be based on the science as defined in Groundwater Sustainability Plan regulations.

In summary, SCWC members respectfully request formation of Groundwater Sustainability Agencies for Sonoma County, supported by Technical Advisory Committees, using the concepts that we have outlined in this letter.

Thank you for your considering our proposals,

Jane

 

October 00, 2016

To

Please distribute this letter to all …. (Board, Council, etc members).

Paragraph with intro on group/individual sending letter …..

Sonoma County will soon be forming Groundwater Sustainability Agencies (GSAs) as specified by the Sustainable Groundwater Management Act of 2015 (SGMA).

(“I”, “we”, Whoever is signing it) …. have/has grave concerns about the success of the GSAs, if organized without serious consideration of local circumstances. SGMA states that GSAs are to be formed by one or a combination of several local agencies, but in Sonoma County, local agencies represent populations that rely almost entirely on surface water drawn from the Russian River. Those who rely on groundwater, such as farmers and rural residents who know the most about it and are the most concerned about sustainability, may have no seat at the table.  This situation may be unique in the State of California, requiring a different GSA-formation model to ensure representation of groundwater users.

The County’s local agencies include County government, the surface water-producing and water-distributing Sonoma County Water Agency (SCWA), which sells that water to other jurisdictions, representing most of the County’s towns and cities. The following facts outline the situation:

  • The Sonoma County Board of Supervisors is also the SCWA Board of Directors.
  • SCWA’s contractors include the County’s most populous urban areas: Santa Rosa, Windsor, Cotati, Rohnert Park — all in the Santa Rosa Plain groundwater basin, and Petaluma, in the Petaluma Valley groundwater basin.
  • The City of Sonoma, and the Valley of the Moon Water District in the Sonoma Valley groundwater basin, also receive Russian River water deliveries.

Virtually all of Sonoma County’s mutual decision-making about water supplies, wastewater treatment, and related issues takes place in councils that consist of representatives from these same agencies and jurisdictions. The councils also include representatives from another county, since SCWA sells Russian River water to Marin County water agencies (North Marin and Marin Municipal Water Districts).[1]

In Sonoma County the only urban areas that do not substantially rely on surface water supplies are Sebastopol, Healdsburg and the unincorporated towns of Penngrove, Graton, Bodega, and Bodega Bay. These towns and cities are not represented on the councils described above. Excepting Sebastopol, none are in an identified scarcity area requiring formation of a GSA.

The GSA board will be a powerful force in Sonoma County communities. Decision makers need input from agricultural and domestic well owners, mutual water systems dependent on wells, water-focused environmental groups, and Sonoma Resource Conservation District (RCD) if policies are to be cost-effective, science based, inclusive of all impacts, efficient and have buy-in from the large percentage of ground-water users in our groundwater basins.

(Group or organization, “I” or “we”, or “our members”) … submit that Sonoma County’s unique relationship to surface and groundwater supplies requires that the GSAs be formed with great care. In particular, they should include groundwater users and technical advisors with pertinent expertise. We believe that this will lead to decisions and actions based on facts and full scientific assessments. In addition, we feel that growing climate uncertainty requires technical expertise for guiding groundwater policy and decision-making.

We are concerned that a GSA consisting entirely of elected officials or political appointees will:

  • Have limited knowledge and experience on water supply other than wholesale and retail supply of surface water (primarily the Russian River);
  • Have no knowledge, or very limited knowledge of hydrology, geology, land-use planning and other fields of great importance for water supply issues, and especially for establishing groundwater sustainability programs;
  • Be forced to rely unduly on staff, which has yet to be assigned, defined, or funded. Local urban staffs may lack technical expertise in climate, water, and sustainability fields;
  • Represent jurisdictions with priorities based on local interests, such as maintaining their allotments based on surface water supplies;
  • Leave out direct stakeholders and well users, who depend on groundwater sustainability and whose involvement is necessary to fulfill SGMA goals.

Potential Sonoma County GSA Composition:

GSAs might include elected officials from the surface-water dependent jurisdictions discussed in the foregoing, with the possible addition of appointed stakeholders, such as Resource Conservation District personnel; rural and agricultural well owners; mutual water system operators; environmental group representatives, others (“at large”); and appointed technical experts.

Staff might be drawn from SCWA, local jurisdictions, Utility Districts, DWR, or might be new hires.

A Conceptual GSA Formulation

In our view, a GSA for each Sonoma County basin should consist of 9 to 11 members, comprising:

  1. Elected officials representing as many as 5 Sonoma County authorities, including SCWA and at least one groundwater-dependent jurisdiction.

Representatives other than SCWA should rotate every 3-5 years, to keep all jurisdictions involved.

  1. Appointed stakeholders, representing those who will be directly impacted by GSA decisions and able to affect groundwater sustainability, including:
  • Agricultural well owner(s) (potentially Sonoma RCD, others)
  • Rural domestic well owners
  • Well-dependent mutual water systems
  • Water-focused environmental organizations (local/national)
  • Independent technical expertsTechnical Advisory Committee:Members of such a Technical Advisory Committee (TAC) could be drawn from:
  • We understand that SGMA allows a GSA to appoint an advisory committee to provide technical expertise.
  • Initial candidates for such appointments should be selected from current members of the Sonoma Valley and Santa Rosa Plain Basin Advisory Panels, organized under AB 3030.
  • SCWA staff or utility departments with specialization in groundwater related science
  • Basin Advisory Panel members
  • Independent consultants
  • Academic/scientific experts
  • Two or three representatives from jurisdictions reliant on wells
  • Ag well owners
  • Domestic well owners
  • Mutual water company representatives
  • Environmental representatives
  • Scientific experts should represent fields such as:
  • hydrology, including an expert on hydrologic modeling
  • geology, including expertise on sedimentary and bedrock geology
  • wetlands biology and fisheries biology
  • land use planningOur experience is that advisory groups appointed by elected officials have little power to guide decision making, however. If experts serve at the pleasure of an appointing board, their effectiveness may be severely limited. We therefore advise that the GSA powers relative to the advisory board should be defined by governing rules, such as:
    • Requirement for a supermajority GSA vote to reject a TAC recommendation; and
    • Findings in support of GSA votes or actions on TAC recommendations, whether negative or positive, must be put in writing, and they must be based on the science as defined in Groundwater Sustainability Plan regulations. We thank you for your consideration of our proposals.
    • We respectfully request that you support formation of Groundwater Sustainability Agencies for Sonoma County, supported by Technical Advisory Committees, using the concepts that we have outlined.

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