HomeMy WebLinkAbout5.9.22 Board Correspondence - FW_ Corning Sub-basin Groundwater Sustainability Agency Committee Meeting- May 11, 2022 (2)
From:Paulsen, Shaina
To:BOS
Subject:Board Correspondence - FW: Corning Sub-basin Groundwater Sustainability Agency Committee Meeting- May 11,
2022
Date:Monday, May 9, 2022 8:07:48 AM
Attachments:22.05.11_CSGSA_Agenda_FINAL.pdf
Please see Board Correspondence below.
Shaina Paulsen
Associate Clerk of The Board
Butte County Administration
25 County Center Drive, Suite 200, Oroville, CA 95965
T: 530.552.3304 | F: 530.538.7120
From: Lisa Hunter <LHunter@countyofglenn.net>
Sent: Sunday, May 8, 2022 9:32 AM
Subject: Corning Sub-basin Groundwater Sustainability Agency Committee Meeting- May 11, 2022
ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening
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attachments, clicking on links, or replying.
Please see the attached Corning Sub-basin Groundwater Sustainability Agency Committee Meeting
agenda.
Regular Meeting of the Corning Sub-basin GSA Committee
May 11, 2022 | 9:30 a.m.
Glenn-Colusa Irrigation District Main Pump Station
7854 County Road 203, Orland, CA 95963
And
Teleconference
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Or call in (audio only)
+1 323-676-6164,,349754778# United States, Los Angeles
Phone Conference ID: 349 754 778#
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Learn More | Meeting options
________________________________________________________________________________
The agenda and meeting packet (when available) can also be found on the Glenn County website at:
https://www.countyofglenn.net/resources/minutes-agendas-water/corning-sub-basin-groundwater-
sustainability-agency-committee-may-11
Best Regards,
Lisa Hunter
Glenn County
Water Resource Coordinator
(530) 934-6540 (office)
County of Glenn
Glenn-Colusa Irrigation District
Monroeville Water District
Notice and Agenda
Regular Meeting of the Corning Sub-basin GSA Committee
May 11, 2022 | 9:30 a.m.
Glenn-Colusa Irrigation District Main Pump Station
7854 County Road 203, Orland, CA 95963
And
Teleconference
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Or call in (audio only)
+1 323-676-6164,,349754778# United States, Los Angeles
Phone Conference ID: 349 754 778#
Find a local number | Reset PIN
Learn More | Meeting options
________________________________________________________________________________
1. Call to Order
2. Roll Call
3. Meeting Minutes
a. *Approval of April 13, 2022 meeting minutes
4. Period of Public Comment
5. Staff Reports
6. Presentation: Land IQ
7. Discussion on Legal Counsel to represent CSGSA as needed
8. Corning Subbasin Groundwater Sustainability Plan
a. Discussion on Corning Subbasin Groundwater Sustainability Plan implementation
and next steps
225 N. Tehama St. 530.934.6540
9. Corning Subbasin Advisory Board Report
10. Discussion on Executive Order N-7-22
a. *Approve Well Permit Acknowledgement Form and authorize staff to finalize
process with the Glenn County Environmental Health Department
11. Corning Sub-basin GSA 2022/2023 Budget
a. Discuss Short Term Funding Strategy
b. Provide direction on a proposed agreement among member agencies to fund
specific tasks or explore other potential options to meet short term funding needs
12. Discussion on Funding Mechanisms for GSP Implementation
a. *Appoint an ad hoc committee to develop and release a Request for Proposals to
solicit a consultant to develop and implement one or more funding mechanisms
for Corning Subbasin GSP implementation
13. Corning Sub-basin GSA Committee Member Reports and Comments
14. Next Meeting
15. Adjourn
A complete agenda packet, including back-up information, is available for public inspection during normal work hours at 225
North Tehama Street, Willows, CA 95988. After posting of this Meeting Agenda, the public may request copies of support
information for public agenda items listed.
In compliance with the Americans with Disabilities Act, The Corning Sub-basin GSA Committee will make available to persons
with a disability disability-related modification or accommodations. Notification two days prior to the meeting will enable the
Corning Sub-basin GSA Committee to make arrangements to provide reasonable accommodations. If requested, this document
and other agenda materials can be made available in an alternative format for persons with a disability who are covered by the
Americans with Disabilities Act. Contact Lisa Hunter at 530-934-6540.
CERTIFICATION: Pursuant to Government Code § 54954.2 the agenda for this meeting was properly posted on or before 9:30
am on May 8, 2022.
Page | 2
County of Glenn
Glenn-Colusa Irrigation District
Monroeville Water District
Notice and Agenda
Regular Meeting of the Corning Sub-basin GSA Committee
May 11, 2022 | 9:30 a.m.
Glenn-Colusa Irrigation District Main Pump Station
7854 County Road 203, Orland, CA 95963
And
Teleconference
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Or call in (audio only)
+1 323-676-6164,,349754778# United States, Los Angeles
Phone Conference ID: 349 754 778#
Find a local number | Reset PIN
Learn More | Meeting options
________________________________________________________________________________
1. Call to Order
2. Roll Call
3. Meeting Minutes
a. *Approval of April 13, 2022 meeting minutes
4. Period of Public Comment
5. Staff Reports
6. Presentation: Land IQ
7. Discussion on Legal Counsel to represent CSGSA as needed
8. Corning Subbasin Groundwater Sustainability Plan
a. Discussion on Corning Subbasin Groundwater Sustainability Plan implementation
and next steps
225 N. Tehama St. 530.934.6540
9. Corning Subbasin Advisory Board Report
10. Discussion on Executive Order N-7-22
a. *Approve Well Permit Acknowledgement Form and authorize staff to finalize
process with the Glenn County Environmental Health Department
11. Corning Sub-basin GSA 2022/2023 Budget
a. Discuss Short Term Funding Strategy
b. Provide direction on a proposed agreement among member agencies to fund
specific tasks or explore other potential options to meet short term funding needs
12. Discussion on Funding Mechanisms for GSP Implementation
a. *Appoint an ad hoc committee to develop and release a Request for Proposals to
solicit a consultant to develop and implement one or more funding mechanisms
for Corning Subbasin GSP implementation
13. Corning Sub-basin GSA Committee Member Reports and Comments
14. Next Meeting
15. Adjourn
A complete agenda packet, including back-up information, is available for public inspection during normal work hours at 225
North Tehama Street, Willows, CA 95988. After posting of this Meeting Agenda, the public may request copies of support
information for public agenda items listed.
In compliance with the Americans with Disabilities Act, The Corning Sub-basin GSA Committee will make available to persons
with a disability disability-related modification or accommodations. Notification two days prior to the meeting will enable the
Corning Sub-basin GSA Committee to make arrangements to provide reasonable accommodations. If requested, this document
and other agenda materials can be made available in an alternative format for persons with a disability who are covered by the
Americans with Disabilities Act. Contact Lisa Hunter at 530-934-6540.
CERTIFICATION: Pursuant to Government Code § 54954.2 the agenda for this meeting was properly posted on or before 9:30
am on May 8, 2022.
Page | 2
County of Glenn
Glenn-Colusa Irrigation District
Monroeville Water District
Corning Sub-basin GSA Committee
Meeting Materials
May 11, 2022 | 9:30 a.m.
Glenn-Colusa Irrigation District Main Pump Station
7854 County Road 203, Orland, CA 95963
And
Teleconference
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Or call in (audio only)
+1 323-676-6164,,349754778# United States, Los Angeles
Phone Conference ID: 349 754 778#
Find a local number | Reset PIN
Learn More | Meeting options
________________________________________________________________________________
1. Call to Order
The Chair will call the meeting to order.
2. Roll Call
Staff will conduct roll call.
Corning Sub-basin GSAPage 1
225 N. Tehama St. 530.934.6540
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3. Meeting Minutes
a. *Approval of April 13, 2022 meeting minutes
Draft meeting minutes are attached.
Attachments:
April 13, 2022 draft meeting minutes
Corning Sub-basin GSAPage 2
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County of Glenn
Glenn-Colusa Irrigation District
Monroeville Water District
Corning Sub-basin GSA Committee
Meeting Minutes
April 13, 2022 | 9:30 am
Glenn-Colusa Irrigation District Pump Station
7854 County Rd 203, Orland, CA 95963
and
Teleconference
1. Call to Order
John Amaro called the meeting to order at 9:33 a.m.
2. Roll Call
Party Representative Member Agency
X Tom Arnold County of Glenn
X Grant Carmon County of Glenn
X John Amaro Glenn-Colusa Irrigation District
X Pete Knight Glenn-Colusa Irrigation District
X Julia Violich (9:52) Monroeville Water District
Seth Fiack Monroeville Water District
Lisa Hunter conducted roll call as noted above.
3. AB 361 Open Meetings: State and Local Agencies: Teleconferences
a. *Discuss and consider approval of Resolution 2022-04 Resolution to Implement
Teleconferencing Requirements During a Proclaimed State of Emergency
Mr. Amaro introduced the item. No further discussion was heard.
On a motion by Mr. Arnold, seconded by Mr. Carmon, it was unanimously approved by
members present to adopt Resolution 2022-04 Resolution to Implement
Teleconferencing Requirements During a Proclaimed State of Emergency
4. Meeting Minutes
a. *Approval of March 9, 2022 meeting minutes
No corrections or comments were made on the draft minutes.
On a motion by Mr. Carmon, seconded by Mr. Knight, the meeting minutes of March 9,
2022 were unanimously approved as presented.
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225 North Tehama Street Willows, CA 95988 530.934.6540
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5. Period of Public Comment
Mr. Arnold reported that the Rangeland Association conveyed to him concerns
regarding the funding source for the Corning Subbasin.
6. Staff Reports
Holly Dawley reported that Land IQ is available to provide a presentation at the
May 11, 2022 Corning Sub-basin GSA (CSGSA) meeting. Ms. Dawley asked if the
CSGSA or the Corning Subbasin Advisory Board (CSAB) is the most appropriate
venue for the presentation. Discussion ensued. It was decided the presentation
would be given to the CSGSA and staff could reach out to the Tehama GSA to
determine interest in a presentation at the CSAB.
7. *Approve 2022 Corning Sub-basin GSA Committee meeting schedule
Mr. Amaro introduced the item. Staff recommended Option 2, setting a monthly
meeting schedule and cancel specific meetings if there are no business items to
discuss.
On a motion by Mr. Carmon, seconded by Mr. Arnold, Option 2 of the 2022 Corning Sub-
basin GSA Committee meeting schedule was approved unanimously by members
present.
8. Discussion on Legal Counsel to represent the CSGSA as needed
Ms. Hunter reported that Glenn County, County Counsel has suggested the
CSGSA seek the services of an experiences water attorney rather than rely on
County Counsel, who currently contracts with outside counsel on water-related
matters due to the complexity of the topic. She also noted, it will be important to
consider how these services will be paid for.
Mr. Knight asked if there might be an opportunity to share counsel with Tehama
County. Ms. Hunter shared that generally, each GSA retains separate counsel, but
that option could be explored. Mr. Carmon stated he is pleased with the services
Valerie Kincaid provides for the Glenn Groundwater Authority and Glenn County
and recommended asking if she would be interested in representing the CSGSA.
Mr. Arnold asked if there would be a conflict; whereby discussion ensued.
Staff was directed to reach out to Ms. Kincaid to determine interest in
representing the CSGSA. It was clarified that grant funding is not expected to be
available for these services.
9. Corning Subbasin Groundwater Sustainability Plan
a. Discussion on Corning Subbasin Groundwater Sustainability Plan implementation
and next steps
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Mr. Amaro introduced the item and indicated no comments have been received
on the GSP. Ms. Hunter noted the comment period is open until April 23, and she
expects at least one comment letter will be submitted. For GSPs that have been
through this process already, comments tended to be submitted at the end of the
comment period. She further clarified, these comments are intended to provide
DWR guidance while reviewing the GSP, and it is helpful for the GSA to be aware
of such comments and consider them during project planning, annual reports,
and the five-year updates.
Ms. Hunter encouraged members and the public to utilize the Annual Report on
the SGMA Portal as a resource. The portal contains the complete Annual Report,
summary information, and monitoring network information, including hydrographs
with the groundwater levels, minimum thresholds, and measurable objectives.
10. Corning Subbasin Advisory Board Report
Mr. Amaro stated the discussion at the April 6, 2022 meeting revolved around the
Annual Report. Mr. Carmon noted the consultant presented the summarized
Annual Report and answered questions. There were some concerns with some of
the estimates for groundwater use, which will be explored in the future.
Mr. Carmon shared the Tehama County portion of the basin reported they will
have a 29 cent per acre fee to get the GSA running, and a consultant will be hired
to put together well information to support a well head fee. He encouraged the
CSGSA to take action to have funding available for immediate tasks. Discussion
ensued on fee development, funding needs, and project and management action
development.
11. Discussion on Executive Order N-7-22
Mr. Amaro introduced the item and Ms. Hunter reviewed that some other GSAs plan
to use an Acknowledgment Form which is a checklist that the permittees reviews
and signs. Mr. Arnold stated that under the moratorium, the County is currently
allowing replacement wells, which would need GSA approval. Mr. Carmon
suggested using the Acknowledgment Form, consistent with the direction of the
Glenn Groundwater Authority. Ms. Hunter reviewed potential options for the
procedure and communication between the GSA and the Environmental Health
Department (the local permitting agency).
Mr. Carmon suggested a joint GSA/County policy to approve wells based on location
and well depth. It was clarified this may be a longer-term goal.
Mr. Carmon stated it seems reasonable to follow the current county policy for
replacement wells while the moratorium is in place.
The item will be brought back for further discussion.
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12. Discussion on Funding Mechanisms for GSP Implementation and Short-Term Funding
Options
Mr. Amaro noted this topic was discussed during Item 10. He summarized direction
to staff to invite Land IQ to make a presentation and funding mechanisms will be
explored. The Proposition 26 mechanism may provide for more immediate funding
for GSA administration and Proposition 218 will also be explored further.
Mr. Knight asked if a consultant and attorney will be needed to move forward. Ms.
Hunter encouraged discussion on how to fund the short-term needs. Mr. Knight
inquired about a cost estimate; whereby discussion ensued on short-term funding
needs and priorities, including funding mechanisms and legal expenses. Ms.
Hunter emphasized the agency should plan to self-fund, possibly with member
agencies contributions for approximately one year before fees would be received
through any type of assessment.
A Technical Memorandum written by West Water will be available by the end of
April to facilitate additional discussion on funding mechanisms.
The CSGSA requested figures for immediate short term funding needs and longer-
term needs for the next meeting.
13. Corning Sub-basin GSA Committee Member Reports and Comments
Ian Turnbull encouraged the members to review the Glenn County General Plan
Update that is nearly complete and emphasized the connection between land use
planning and water management. Mr. Carmon stated he has had conversation
with the Planning team and consultant and some wording may be added that
permanent crops are discouraged on the westside and if permanent crops are
planted, they must prove water sustainability. Mr. Turnbull expressed his
concerns and recent developments with lands generally west of the traditional
State Responsibility Area (SRA) boundary.
Jaime Lely expressed concern that if a per acre fee is placed on lands, particularly
dry lands, it forces landowner to consider other options in order to afford paying
those fees. The other options include higher profitability crops which also use
more groundwater. She reiterated that many landowners have limited
groundwater availability. She further inquired if an ad hoc committee was going
to work on aspects to fund this. Ms. Hunter responded that it had been decided
to have the discussions at Board meetings because this group is small, so full
Board discussion would be more efficient. Ms. Lely spoke to the large amount or
dry land farming in the basin and a lack of representation for those landowners
during the fee discussions. Mr. Carmon encouraged the landowners to attend the
Board meetings and Ms. Dawley clarified that the Glenn County and Tehama
County portions of the basin are pursuing separate funding mechanisms.
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14. Next Meeting
The next CSGSA is scheduled for May 11, 2022 at 9:30 a.m.
15. Adjourn
The meeting was adjourned at 10:51 a.m.
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4. Period of Public Comment
Members of the public are encouraged to address the Corning Sub-basin GSA Committee.
Public comment will be limited to three minutes. No action will be taken on items under
public comment.
5. Staff Reports
Staff from members of the Corning Sub-basin GSA will provide relevant updates, such as
a brief status update of GSP implementation, grant agreement, and project agreement.
Reminders and clarifications may be made, and direction may be provided to staff.
6. Presentation: Land IQ
Over the past several months, discussion has taken place on options and available tools
to better understand land and water use within the subbasin to support GSA discussions
on potential fee options and project and management action planning. Land IQ is a tool
that has been used state-wide and locally for various projects. Joel Kimmelshue will
provide a presentation to share more information about Land IQ.
7. Discussion on Legal Counsel to represent CSGSA as needed
As the GSA moves forward, it is important to consider formalizing an arrangement for Legal
Counsel to represent the CSGSA on an as-needed basis. At the March 9, 2022 meeting,
there was general consensus to request Glenn County, County Counsel to provide these
services and consult with outside counsel as needed.
At the April 13, 2022 meeting, staff reported that Glenn County, County Counsel suggested
seeking the services of an experienced water attorney. At that meeting, staff was directed
to reach out to Valerie Kincaid, with Paris Kincaid Wasiewski, LLP to determine if she would
be interested in providing services to the CSGSA.
Staff has reached out to Ms. Kincaid, who indicated the firm would be interested in serving
as counsel to the CSGSA. Anticipated expenses would be dependent on the level of
support the GSA requires, but could include meetings, research, memos, litigation, and
other deliverables directed by the Committee. Priorities that will likely need counsel review
and input will be discussed in further detail during Item 11. The 2022 Rate Sheet is
attached.
Staff requests direction on the following options:
Request a more formal proposal from Paris Kincaid Wasiewski
OR
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Work with Ms. Kincaid to outline next steps to enter into an agreement Paris
Kincaid Wasiewski
OR
Reach out to additional firms to gauge interest in providing services to the
CSGSA
Additional updates may be provided, potential options will be explored, and direction may
be provided to staff.
Attachments:
Paris Kincaid Wasiewski 2022 Rate Sheet
Corning Sub-basin GSAPage 9
5/11/22 Meeting Materials
RATE SHEET 2022
The Firm is compensated for its legal services on an hourly basis, billed on prorated
increments of 1/10 an hour. Invoices are broken down and organized by client and specific
assignment to assist in the tracking of costs incurred and services performed related to specific
matters. The Firm sets its hourly rates based on experience of each attorney and market rates.
A. Partner Rate: $400/hour
B. Senior Counsel Rate: $350/hour
C. Associate Rate: $300/hour
The Firm does not charge a separate hourly rate for paralegal or secretary time;
although this resource has tremendous value, our Firm includes these costs in overhead. Any
outside counsel costs will be billed directly to the client, upon prior notification and approval.
The Firm does not charge for any expense that is considered overhead, including telephone
calls, cellular service, postage, fax or document reproduction services unless outsourced due to
a need for an unusual size, shape or volume. The Firm charges hourly rates above for travel
time, but no other mileage charges are accrued.
1
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8. Corning Subbasin Groundwater Sustainability Plan
a. Discussion on Corning Subbasin Groundwater Sustainability Plan implementation
and next steps
The Corning Subbasin GSP was submitted to DWR on January 28, 2022 and posted by
DWR on February 7, 2022 initiating a 75-day public comment period. The comment
period ended April 23, 2022. Seven comments were received during the public comment
period, and one comment was received after the comment period ended. The GSP can
be accessed on the SGMA Portal at: https://sgma.water.ca.gov/portal/gsp/preview/94
The Corning Subbasin GSP Annual Report, developed by Montgomery & Associates on
behalf of the GSAs in the Corning Subbasin, was completed and submitted to DWR on
April 1, 2022, meeting the statutory deadline. No comments have been received. The
Annual Report can be found on the SGMA Portal at:
https://sgma.water.ca.gov/portal/gspar/preview/90
Discussion may be held on the shift from GSP planning to GSP implementation. The
CSGSA may consider concepts, goals, and priorities for initial GSP implementation and
may provide direction to staff.
Attachments:
Comments submitted to the SGMA Protal on the Corning Subbasin GSP
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April 23, 2022
California Department of Water Resources
1416 9th Street
Sacramento, CA 95814
Re: Corning Subbasin Groundwater Sustainability Plan
To whom it may concern:
AquAlliance, the California Sportfishing Protection Alliance, and the California Water Impact
Network (hereinafter AquAlliance) submit the following comments and questions on the Corning
rning
the Plan that require significant changes to the document, without which the public and
policymakers are truly left in the dark and dangerous consequences are obfuscated.
Introduction
The goal of the Sustainable Groundwater Management Act (SGMA) is to sustainably manage
groundwater resources for long-term reliably and multiple economic, social, and environmental
benefits for current and future beneficial uses based on the best available science (Water Code
113). The people of California have a primary interest in the protection, management, and
reasonable beneficial use of the water resources of the state, both surface and underground, and
management goals. Proper management of groundwater resources will help protect
communities, farms, and the environment against prolonged dry periods and climate change,
while preserving water supplies for existing and potential beneficial use. Failure to manage
groundwater to prevent long-term overdraft infringes on overlying and other proprietary rights
to groundwater.
established as state policy that every human being has the
right to safe, clean, affordable, and accessible water adequate for human consumption, cooking,
and sanitary purposes (WC 106.3(a)). State agencies, including the California Department of
Water Resources (CDWR), the State Water Resources Control Board (SWRCB), and the State
Department of Public Health, are required to consider this state policy when revising, adopting,
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AquAlliance Comments Corning GSP
or establishing policies, regulations, and grant criteria when those policies, regulations, and
criteria are pertinent to the uses of water (WC 106.3(b)). The Water Code also creates a state
policy that the use of water for domestic purposes is the highest use of water and that the next
highest use is for irrigation (WC 106). The Groundwater Sustainability Agencies (GSAs) were
created by SGMA and are delegated by the state the authority to create and implement a
Groundwater Sustainability Plan (GSP), which makes the GSA(s) a political subdivision of the
state. Therefore, approval of any SGMA GSP created by a GSA(s) or county agency, which is then
approved by the CDWR and the SWRCB, must be consistent with the state policies that protect
to safe and available supply of groundwater for all beneficial uses.
Implementation of the SGMA requires the creation of a GSP that provides for the development
and reporting of those data necessary to support sustainable groundwater management,
includin- and long-term trends of
resolve disputes regarding sustainable yield, beneficial uses, and water rights. A presumption
perpetuate the management errors of the past. That the design of the Corning Subbasin GSP
sustainability monitoring program requires years of declining groundwater levels before an
undesirable result can occur suggests that the past mismanagement practices will persist. The
1
November 2021 Corning Subbasin Final GSP fails to meet the SGMA goal of water resource
sustainability and protection of the water rights of all beneficial users and uses.
The proposed sustainable management criteria presented in the Corning GSP fail to demonstrate
as required by SGMA that the goal of groundwater sustainability is achievable and will occur
within 20 years of GSP adoption for: (1) chronic lowering of groundwater levels, (2) reduction of
groundwater storage, (3) degraded water quality, (4) depletions of interconnected surface
waters, and (5) inelastic land subsidence. The Final Corning GSP fails to protect the beneficial
uses for all users of groundwater in the subbasin because of the following:
The final plan sets the minimum thresholds (MTs) for unreasonable results in the
management the groundwater levels at depths that can result in 16% or more of the
domestic wells going dry for sustained periods, if not permanently.
The final plan requires without analysis or justification that before an unreasonable result
can occur, the MTs for a sustainability indicator must be continuously and simultaneously
exceeded for 24 months (2 years) at a minimum of 20% at representative groundwater
monitoring wells.
The final plan estimates that sustainable management of the groundwater levels and
groundwater storage with the projected 2070 scenario will allow for a cumulative change
in storage of -19,700 acre-feet (af) in the next 50 years, which is contrary to the estimated
Historical baseline cumulative surplus from 1974 to 2015 of 290,300 af.
The estimated difference between the Historical average annual and the projected 2070
average annual change in storage is -7,200 acre-feet per year (afy), or 360,000 af by 2070.
1
California Groundwater Basin number 5-021.51, part of the Sacramento Valley Groundwater Basin.
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The 2070 scenario estimated maximum annual change in storage during critically dry and
dry water years is -41,800 afy, approximately 50% greater than the Historical baseline
change of -27,450 afy, and over 100 times the 2070 annual average loss in groundwater
storage.
The final plan operational flexibility (OF) for sustainable management, the difference
between the depths of the management objectives (MOs) and the MTs, is sufficient to
allow for an average decline in groundwater levels approximately 3 times greater
than the difference between the MOs and lowest groundwater levels since 2012 before
an undesirable result can be declared.
The final plan OF volume is large enough to allow for groundwater level decline for
5 continuous critically dry and dry water years before the minimum threshold depth is
reached, which must then be followed by two more consecutive years with levels
continuously below the MTs before an undesirable result needs to be declared.
The final plan assumes that sustainable management of the subbasin will allow
groundwater pumping to increase by 36,300 afy above the Historical baseline, a 27%
increase, with 96% of the increase going to agricultural uses.
The final plan assumes that sustainable management of the subbasin with the 2070
scenario will result in annual average net stream gains (groundwater discharge minus
stream seepage) of -4,600 afy, which is -37,700 afy below the Historical baseline of a
+33,100 afy. This is a loss of approximately -114% in annual average net stream gains over
the Historical baseline.
The final plan assumes that sustainable management of the subbasin with the 2070
scenario will result in annual average net stream gains of -37,700 afy below the Historical
baseline while groundwater pumping increases 36,300 afy above the Historical baseline, a
change ratio of -104%. In other words, the proposed 2070 scenario increase in
groundwater pumping will cause a decline in interconnected surface waters that exceeds
the pumping increase.
The final plan requirement for simultaneous, continuous exceedance of the MT at
multiple representative monitoring wells can result in significant magnitudes and
expansive areas of decline in groundwater levels, groundwater storage, water quality,
interconnected surface waters, and possibly surface elevations (inelastic subsidence) as
long as one of the monitored stations in the group MT.
In other words, there is no limit to decline in the beneficial uses of groundwater if
measurements in one of the monitoring stations within a group is above the MT at least
once every 24 months.
The final plan fails to analyze, monitor, or consider the potential impacts to water quality
from the proposed allowable changes in groundwater levels and storage, except for one
constituent, salinity. Although the final plan calls for coordination in management of
e what the MTs
are for all the potential contaminants of concern in the Corning subbasin, or what and
how GSP management actions will be taken whenever a water quality impact is
identified.
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The final plan requires that at least 25% of the 15 RMP water quality network monitoring
wells, i.e., 3 wells, must exceed the MT for 2 consecutive years where it is established that
the GSP implementation is the cause of the exceedance to trigger an undesirable resul t.
The justification for requiring water quality exceedance in multiple wells for multiple
quality degradation
before the Corning GSAs will act to prevent an undesirable result. The requirement that
someone must prove that the GSP implementation caused the water quality exceedance
The final plan sets the MT rate of inelastic subsidence that appears to exceed the current
conditions while providing no current assessment of the sensitivity of local infrastructure
to subsidence.
frequent monitoring of subsidence
benchmarks or monitoring of critical infrastructure, but instead leaves the responsibility
of subsidence monitoring and analysis to others with the frequency of reporting
dependent on the work schedules and funding of DWR and others.
The Final Corning GSP Fails to Comply with SGMA and the Water Code.
The following sections provide expanded discussions of the deficiencies listed above regarding
how the Corning GSP fails to protect the beneficial uses for all users of groundwater in the
subbasin.
1. The Corning GSP sets the MTs for unreasonable results in the management of groundwater
levels at depths that can result in 16% or more of the domestic wells going dry for sustained
periods, if not permanently, Section 6.6.2.2 (pages 6-21 to 6-26, pdf 430 to 435). This could
possibly result in 315 of the 1,970 domestic wells in the subbasin going dry, see well count in
Table 2-5 (page 2-34, pdf 100).
The representative monitoring point (RMP) network of wells for measuring groundwater
levels includes 37 shallow wells and 21 deep wells, Section 5.2.4 (pages 5-7 to 5-11, pdf 369
to 374). The RMP wells are subdivided into three regions: stable, slight decline, and declining,
based on the historical stability of groundwater levels, Figures 6-1 and 6-2 (pages 6-12 and 6-
13, pdf 421 and 422, and AquAlliance Exhibit 1. The MTs for the RMP groundwater level wells
are set based on whether the recent historical (2010 to 2019) groundwater levels are stable
or declining. Minimum thresholds were set using one of the two criteria (page 6-8, pdf 417):
elevations (stable wells): Minimum fall groundwater elevation since 2012 minus 20-foot
buffer.
elevations (declining wells): Minimum fall groundwater elevation since 2012 minus 20% of
minimum groundwater level depth.
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Both criteria appear to be arbitrary and designed to allow for the groundwater level to
decline below the recent lowest elevation measured during a drought. This will likely subject
many domestic well owners to experience their lowest groundwater levels with all the
accompanying negative impacts: dry wells, poor water quality, higher pumping cost, etc.
AquAlliance Exhibit 1-2 has a summary at the bottom of the table of the average MOs and
MTs depths and depth differences for each class of RMP monitoring well taken from Tables 5-
2, 5-7 and 6-2 (pages 5-8 and 5-9, 5-37, and 6-15 and 6-16, pdf 370-371, 399, 424-425). The
average difference in depth in the shallow wells between the MO and the lowest
groundwater elevation since 2012) (MO 2012) ranges from 4.1 feet to 15.9 feet, with the
basin-wide average at 6.9 feet. The difference in the shallow well elevation from the lowest
groundwater levels since 2012 to the MTs (2012 MT) ranges from 16.5 feet to 23.12 feet,
with a basin-wide average of 17.8 feet. The shallow well MTs allow for a decline in depth
ranging from 2.6 to 5.9 times greater than the historical decline from the MOs to the 2012
low \[(MO-MT)/(MO-2012)\], with a basin-wide average of 3.7 times, or 370% greater. In other
words, domestic wells that on average experience a historical decline of 6.9 feet will now be
allowed to experience an average maximum decline of 25.6 feet. This increase appears to be
significant and unreasonable, and it apparently allows for the dewatering of 16% of the
known domestic wells, or possibly more, because of the requirement for 2 consecutive years
below the MT depth before an undesirable result occurs, Table 6-1 and Section 6.6.4.1 (pages
6-1, 6-34 and 6-35, pdf 416, 443 and 444).
The Corning GSP apparently considers a 370% increase from the average MO-to-MT depths
to be a beneficially practical sustainable management criterion, stating that \[t\]he proposed
minimum thresholds for groundwater elevation will not necessarily protect all domestic wells
because it is impractical to manage a groundwater basin in a manner that fully protects the
shallowest wells (page 6-26, pdf 436). to consider the
shallowest 16%, or 315 wells, unworthy of protection regardless of which wells that have
already gone dry since 2012 (i.e., past droughts) as well as those that will go dry in the future
under Corning GSP sustainability criteria.
2. The Corning GSP does propose to establish a Well Mitigation Program, Section 7.3.2.1 to
7.3.2.7 (pages 7-12 to 7-15, pf 490 to 493) with various objectives and costs estimated at
$100,000 to $500,00 per year, but the specified. The plan states
that this well mitigation program would help identify and avoid impacts to well owners with a
more complete inventory of wells and by the GSAs providing education and outreach to
well owners to deepen or replace wells, Section 7.3.2.1.7 (page 7-15, pdf 493). The outline for
the Well Mitigation Program generally describes determination of which well owners might
benefit from the program:
Eligibility and access documentation to determine which Subbasin residents are eligible to
participate in the mitigation program, well eligibility based on well construction
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parameters, and protocols to determine potential mitigation actions such as well
deepening, repair, or replacement.
The description of the Well Mitigation Program only commits to taking potential mitigation
actions without giving any specifics on how the $500,000 per year cost was determined or
the amount of funds committed to each potential mitigation action, or any matching fund
requirements for eligible well owners.
The Well Mitigation Program in its current form is just a concept, not an actual commitment
to mitigate the impacts from the proposed increased groundwater pumping. The Corning GSP
program. In other words, increased pumping can apparently go forward, without a program
to deepen, repair, or replace impacted domestic wells.
To be a functional mitigation program, the Corning GSAs need to make a firm commitment to
implement the program within the next 3 years as shown in Table 7-3 (page 7-15, pdf 493)
and expand the description of the program to include specific information on the funding
source(s), the availability of these funds (local, state, or federal), the legal requirements for
acquiring the funds, the criteria for prioritizing expenditures, the requirements for eligibility
to receive funds, the funding match requirements for eligible well owners, the criteria for
deciding to deepen, repair a well, add a water quality treatment system, or replace it with
new well construction, the administrative procedures for the program, and the steps a
resident must take to obtain well repair or replacement funds. In addition, the GSP should
address criteria that will be used to evaluate a well that needs to be the deepened, repaired,
2
or replaced to comply with the recent GoN-7-22, and any
additional local agency permitting requirements.
3. The Corning GSP requires that groundwater levels fall below their minimum groundwater
elevation thresholds for 24 consecutive months (2 years) in 20% of the wells before an
undesirable result can be declared, Table 6-1 and Section 6.6.4.1 (pages 6-1, 6-34 and 6-35,
pdf 416, 443 and 444). -
uses and users only occurs when there are 24 continuous months of harm across a broad
area of the subbasin, which then triggers an undesirable result and the need for the GSAs to
take action.
The Corning GSP provides additional language to the definition of a SGMA undesirable result,
noting that part of the definition given in the SGMA regulations. The GSP
lists the six groundwater conditions from Water Code Section 10721 that can trigger an
undesirable result, Section 6.1, (pages 6-2 to 6-4, pdf 411 to 413). The plan then adds the
following explanatory text to the definition of undesirable result:
2
https://www.gov.ca.gov/wp-content/uploads/2022/03/March-2022-Drought-EO.pdf
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Undesirable Result is not defined in the GSP Regulations. However, the description of
undesirable result states that it should be a quantitative description of the combination of
minimum threshold exceedances that cause significant and unreasonable effects in the
subbasin. An example undesirable result is more than 20% of the measured groundwater
levels being lower than the minimum thresholds. Undesirable results should not be
confused with significant and unreasonable conditions. Significant and unreasonable
conditions are physical conditions to be avoided; an undesirable result is a quantitative
assessment based on minimum thresholds. (underline added)
Apparently, the Corning GSP is making a distinctio
undesirable to only a few from a condition that affects many. This seems to be making an
arbitrary threshold on the practical number of residents that can be inconvenienced by a dry
or impaired well. For example, the assumption that it is practical to allow 16% of domestic
wells can go dry in the Corning Subbasin, which is a significant and unreasonable condition
for those residents, but apparently not to the
residents of the subbasin as a whole so as to trigger an undesirable result and the need for
sustainable management action(s). The authority to set the practical threshold of how
many residences can be made to have a significant and unreasonable condition is unclear.
When combined with the 20% requirement for collective MT exceedance for 24 consecutive
months, the GSP sustainability management criterion for chronic lowering of groundwater
levels may violate Water Codes 106, 106.3(a) and 106.3(b) because it fails to prioritize
groundwater for domestic purposes and protect the groundwater in the subbasin to provide
for an adequate supply of safe, clean and affordable water for human consumption, cooking
and sanitary purposes.
4. The Corning GSP 20% of the RMP wells will be selected, or whether
they can be adjacent, discontinuous, or spread across the subbasin. Can there be more than
one 20% group? The monitoring plan does split the groundwater level monitoring network
into 37 shallow and 21 deep wells (greater than 450 feet below the ground surface,(bgs)) so
that suggests that at least two 20% groups are allowed. The reasoning for selecting the 20%
well groups raises several questions:
What are the selection criteria for 20% groups of groundwater level monitoring wells?
Are they based on the portion of the subbasin being monitored by these wells, how
groundwater production in the subbasin is being managed, where sustainability
projects are being implemented, when the groundwater levels wells drop below their
MT elevations, or some combination of these and other criteria?
How many wells are required to make a 20% group? Can it be 8 wells out of the 37
shallow wells, 5 wells from the 21 deep wells, or does it need to be 12 wells from a
total of 58 wells?
How many 20% MT exceedance groups are possible in each aquifer zone, only one, up
to 5, or more?
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Can the areas of the subbasin monitored by multiple 20% groups overlap?
Can a well be in multiple 20% groups at the same time?
Can an undesirable result be declared after 24 months of MT exceedance in the deep
aquifer, but not be declared for the overlying shallow aquifer, or vice versa?
What is the start date of the 24-consecutive-month clock? Does it start on the earliest
day that any one of the 20% wells exceeds its MT, on the day the last of the 20% well
exceeds its MT, or some other intermediate date?
What happens to the start date of the 24-consecutive-month clock if additional RMP
wells exceed their MTs after the day that minimum number of wells needed
for a 20% group? In other words, does the start date begin anew when a well is added
to an existing group?
Are these additional wells made part of the existing group or does a new group have
to be formed once there are enough additional wells to make another 20% group?
If there are multiple 20% MT exceedance groups, how is the determination of an
undesirable result made if the exceedance in any one group is less than 24 months,
but the combined duration of the exceedance for all groups is greater than 24
months?
It is unclear if the wells assigned to a group stay in the same group forever, change
when there are fewer than 20% of the wells in the group, or change when the 24-
month clock stops.
What happens when the locations of the first 20% group of wells cover a large portion
of the subbasin, and then additional MT exceedance wells are clustered with in the
around a local pumping depression in numbers sufficient to form
another 20% group?
Why does the MT exceedance need to be continuous in 20% of the monitoring wells
for 24 months when dewatering of a single domestic or small agricultural well can
cause significant harm to the user(s) if it occurs repeatedly for only a few months?
Why is the dewatering of a domestic and/or small agricultural well for less than 24
months considered a beneficially sustainable practice Water
Code Sections 106 and 106.3(a)?
Why is dewatering of domestic and/or small agricultural wells that might occur
cyclically each summer considered a beneficially sustainable practice, and who is
benefitting? Certainly it is not to the small landowner.
5. AquAlliance Exhibits 2 through 5 are modifications of groundwater, land surface, and surface
water budgets in the Corning GSP. The modifications include columns and rows that calculate
the budget component differences between the average values, differences in the
component values by water year type, calculated sums and differences for groundwater
pumping and storage, stream gains and losses, and the difference between the Historical
baseline and the Current baseline with the Projected 2070 water budget. Columns and rows
in these exhibits have been labeled for these comments.
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AquAlliance Exhibit 2 lists the values and changes in the Historical and projected 2070
groundwater budget components with summaries for groundwater pumping and storage for
the overall average, and the three different water year type groups, critically dry and dry
(CD/D), below normal and above normal (BN/AN), and wet (W). The Historical baseline
average annual groundwater pumping for all year types is 135,900 afy, Exhibit 2-1A (row 20,
column C). Historical baseline pumping increased for CD/D water years by 7% to 145,050 afy
and deceased for the other two water year types (row 20, columns G through J). For the
projected 2070 scenario, the subbasin average groundwater pumping will be increased above
the Historical baseline by 36,300 afy, or 27%, to 172,200 afy, Exhibit 2-2C (row 68, columns D
and E) and Exhibit 2-1B (row 44, column C). Projected 2070 pumping will increase 37,250 afy
during CD/D water years, 38,500 afy for AN/BN years, and 35,300 afy for W years, Exhibit 2-
2C (rows 68, columns E through J).
Increases in groundwater pumping for the 2070 scenario also result in changes in
groundwater storage. The Historical baseline average annual change in groundwater storage
is a positive 6,900 afy, which resulted in a cumulative change in groundwater storage of
290,300 acre-feet (af), Exhibit 2-1A (rows 21 and 22, column C). During Historical CD/D water
years, the storage loss is negative at -27,450 afy (row 21, column E). The 2070 scenario
annual average change in storage is -300 afy with a cumulative change of -19,700 af over 50
years (rows 45 and 46, column C). While the 2070 annual average change in groundwater
increases to -41,800
afy, an additional loss over the Historical baseline of -14,350 afy, Exhibit 2-1B (row 45,
column E) and Exhibit 2-2C (row 69, column E). The additional loss in storage for the 2070
scenario is approximately 39% of the 37,250 afy increase in groundwater pumping (-14,350
afy / 37,250 afy = 0.385 = 39%), Exhibit 2-2C (rows 68 and 69, column E). This additional loss
in groundwater storge during CD/D water years, or drought years, is important because the
change in storage during droughts can be used to establish the depth of the MTs, which will
be discussed below in Comment No. 11.
6. The additional loss in groundwater storage
decrease in the Corning GSP water budget caused by the increase in pumping. The increase in
groundwater pumping also causes a significant decline in the interconnected surface water
flows. AquAlliance Exhibit 2 calculates the change in the net stream gains, i.e., the amount of
groundwater discharging to the streams minus the amount of surface water seeping to
groundwater. For the Historical baseline, the annual average net stream gain is a positive
33,100 afy, Exhibit 2-1A (row 23, column C). In other words, the streams gain flow from
discharging groundwater. There is an assumption that when streams gain flow from
groundwater and the flow changes with the pumping of groundwater, then those streams are
3
interconnected surface waters and subject to SGMA.
3
See these articles about how the disconnection of streams and groundwater results in maximum stream flow losses
that spread as the groundwater depression enlarges.
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The Historical baseline net stream gain is also positive for all water year types (row 23,
columns E through J). In contrast, the 2070 scenario has a net loss in average annual stream
flow of -4,600 afy, Exhibit 2-1B (row 47, column C). This 2070 scenario loss in annual stream
flow continues in the CD/D and BN/AN water years with a maximum loss of -11,000 afy,
Exhibit 2-1B (row 47, columns E through J). Although the 2070 Wet year has a positive net
stream gain of 3,700 afy, it is a -47,200 afy reduction from the Historical baseline wet year
gain of 50,900 afy, Exhibits 2-1A and 2-1B (column I, rows 47 versus 23) and Exhibit 2-2C (row
70, column I).
The 2070 scenario loss in net stream gain is greater than the increase in groundwater
pumping. The 2070 scenario average annual loss in stream flow relative to the Historical
baseline of -37,700 afy is approximately 104% of the 36,300 afy 2070 increase in average
annual groundwater production, Exhibit 2-2C (rows 68, 70 and 71, column C). The 2070
scenario stream flow loss from the Historical baseline continues for the different water year
types ranging from -81% to -134%, Exhibit 2-2C (rows 70 and 71, columns E to J).
The Corning GSP planned increase in groundwater pumping with the 2070 scenario appears
to result in both a loss in groundwater storage and a loss in surface water flows,
Exhibit 2-1B (rows 45, 46 and 47, column C). These losses contrast with the Historical baseline
where annual average for both water budget components is positive, Exhibit 2-1A (rows 21,
22 and 23, column C). The 2070 loss in surface water flow that exceeds the increase in
pumping suggests that the subbasin may be at a hydraulic and ecological tipping point. The
Corning GSP proposed 2070 management of subbasin raises the several questions about the
sustainability of future stream flows:
Brunner P., Cook P. G., and Simmons C. T., 2009, Hydrogeologic controls on disconnection between surface water
and groundwater, Water Resources Research, v. 45, W01422, pp. 1-13.
https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2008WR006953
Brunner P., Cook P.G. and Simmons C.T., 2011, Disconnected Surface Water and Groundwater: From Theory to
Practice, Ground Water, v. 49, no. 4, pp. 460-467.
https://libra.unine.ch/Publications/Philip_Brunner/25762
Cook P.G., Brunner P., Simmons C.T., Lamontagne S., 2010, What is a Disconnected Stream?, Groundwater 2010,
Canberra, October 31, 2010 November 4, 2010, p. 4.
https://www.researchgate.net/profile/Philip-
Brunner/publication/266251504_What_is_a_Disconnected_Stream/links/54dfa2c80cf29666378b9e57/What-is-a-
Disconnected-Stream.pdf
Fox G.A. and Durnford D.S., 2003, Unsaturated hyporheic zone flow in stream/aquifer conjunctive systems, Advances
in Water Resources, v. 26, pp.. 989-1000.
http://www.geol.lsu.edu/blanford/NATORBF/5%20Modeling%20Papers%20of%20Groundwater%20Flow%20of%20S
tream&Aquifer%20Systems/Fox%20et%20al_Water%20Resources_2003.PDF
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Why is a loss in stream flow that exceeds the increase in groundwater pumping by
104% considered a beneficially sustainable management practice?
Shouldne loss in stream flow caused by an increase in pumping be considered an
undesirable result to interconnected surface waters, and a negative impact to the
Public Trust?
proposed 2070 scenario groundwater production in
the Corning Subbasin be reduced below the proposed sustainable yield of 171,800
afy, Section 4.4.6 (pages 4-88 and 4-89, pdf 361 and 362), to prevent the undesirable
results of a significant and unreasonable loss of interconnected surface water flow?
Does the additional loss of surface water proposed by the GSP require a water rights
diversion and storage permit? If yes, where is the point of diversion and what are the
permit conditions?
Does SGMA allow a GSP to reduce surface water flows without a full water availability
analysis that documents the impacts of the reductions on existing water rights,
demonstrates that the minimum surface water flows and by-pass flow requirements
will be met, and shows that ecological and Public Trust resources will be protected?
7. In addition to the calculation of the basin-wide loss in interconnected stream flow with the
2070 scenario, the Corning GSP provides data on the change in stream flows for three major
surface water bodies in the subbasin: the Sacramento River, Stony Creek and Black Butte
Lake, and Thomes Creek, Exhibit 4.
The Sacramento River is the only major stream during the Historical baseline period that had
a positive net gain in flow from groundwater discharge, i.e., an increase in surface flows,
Exhibit 4-1A (row 3, columns B through I). Stony Creek and Black Butte Lake received a small
minor compared to the seepage losses, so
the net stream gain was negative, Exhibit 4-1A (row 4 through 8, columns B through I). For
Thomes Creek, the net stream gain was all negative with apparently no groundwater
discharging to the creek, Exhibit 4-1A (rows 9 through 11, columns B through I). Note,
receive discharge from groundwater can still be affected by changes in
groundwater level and therefore be interconnected, see references listed in footnote 2 of
Comment No. 6.
The projected 2070 scenario exhibits a significant reduction in the net stream gain in all three
of these surface water bodies, which is consistent with the basin-wide change, Exhibit 4-1B.
The Sacramento River will have the greatest change in net stream flow with an annual
average of loss of -63,000 afy, a -178% loss from the Historical baseline, Exhibit 4-2C (row
31, columns B and C). The majority of the subbasin stream flow losses continue with the
Sacramento River for all water year types (row 31, columns B through I). The sum of the
changes in the three surface water bodies is a loss averaging -86,000 afy with the water year
type losses ranging from -57,850 afy to -84,200 afy, Exhibit 4-2C (row 42, columns B through
I). Note that the sum of the losses in net stream gains for these three surface water bodies is
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greater than the basin-wide loss in net stream gains for the annual average and all water year
types; compare Exhibit 4-2C (row 42, columns B through I) with Exhibit 2-2C (row 70, columns
C through J). It is unclear what causes this difference even though the summation of the
change in the net gains from Black Butte Lake.
Including the lake make up for the difference between the two surface water
budgets.
ing both the basin-wide
and the three itemized surface water body water budgets is that the 2070 scenario predicts
significant and unreasonable losses from interconnected surface waters, which should be
considered an undesirable result, and a negative impact to the Public Trust
quantify or analyze the effects of the interconnected surface water loss on beneficial uses of
the surface water. Without the beneficial uses and water availability analyses, the
management of the subbasin should maintain the Historical baseline surface water flows.
Maintaining Historical baseline surface water flows may require reductions in the annual
groundwater pumping below the historical rates because of climate change. AquAlliance
Exhibit 3 compares the Current scenario water budget to the Projected 2070 scenario. The
Current scenario water budget evaluates the existing supply, demand, and change in storage
under the most recently available population, land use, and hydrologic conditions, Section
4.1.3 (page 4-13, pdf 286). The Current water budget shows an increase in annual average
groundwater pumping to 157,900 afy, an increase of 22,000 afy over the Historical baseline
of 135,900 afy. The Current scenario has an annual average net stream gain of 10,000 afy, a
change of -23,100 afy from the 33,100 afy Historical baseline, AquAlliance Exhibits 2-1A and
3-1A (rows 20 and 23, column C). As with the 2070 scenario, the Current scenario ratio of the
change in net stream gain to change in groundwater pumping is negative and greater than
one at -105% (-23,100 afy / 22,000 afy = -1.05 = -105%). This suggests that future climate
changes may cause a reduction in net stream gain even with the Historical baseline rates of
groundwater pumping.
Corning GSP and the management actions should be revised so that the 2070 scenario
groundwater production is made sustainable by not causing losses in interconnected surface
waters. Future subbasin groundwater management should maintain the flows in the subbasin
stream and river to, at a minimum, match the Historical baseline in flow quantity, flow timing
and flow location.
8. AquAlliance Exhibit 5 gives the values for the Land Surface Budget for the Historical baseline,
part A, and the projected 2070 scenario, part B. The differences between the baseline and
the 2070 scenario are given in part C. Overall there is an increase in the total inflow and
outflow with the 2070 scenario, Exhibit 5C (rows 26 and 31, columns C through J). However,
the direction of change is not the same for each water budget component.
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The 2070 scenario inflow for precipitation and applied groundwater both increase over the
Historical baseline, but the applied surface water decreases. For the 2070 scenario the total
outflow increases with the increases in evapotranspiration and overland flow. These
increases in outflow appear to cause the decrease in deep percolation and return flow to
streams, Exhibit 5C (rows 27 and 30, columns C through J). The total change in soil and
unsaturated zone storage from Historical baseline to the 2070 scenario is negative for the
annual average and the BN/AN water year, positive for the CD/D drought water years, and
zero for the wet years, Exhibit 5C (row 32, columns C through J). It is unclear if the loss in
return flow to streams in the Land Surface Budget, Exhibit 5 (row 30), is a part of the net
stream gains component in the Groundwater and Surface Water budgets, Exhibits 2, 3 and 4.
9. The MT depths are apparently calculated assuming the sustainable yield of 171,800 afy for
the 2070 scenario. The Corning GSP calculates a sustainable yield by subtracting the average
annual negative change in annual groundwater storage in the projected 2070 scenario from
the average annual groundwater production, Section 4.4.6 (pages 3-61 and 3-62, pdf 361 and
362), Table 4-15 (page 4-69, pdf 432), and AquAlliance Exhibit 2-1B (rows 44 and 45, Column
C). As discussed in Comments Nos. 6 and 7, the proposed 2070 scenario management of the
subbasin will result in a significant loss in interconnected surface waters while groundwater
pumping is allowed to increase presumably up to this sustainable yield. Note that the
projected pumping during CD/D water years is greater than the sustainable yield at 182,300
afy, AquAlliance Exhibit 2-1B (row 44, column E).
The calculation of the 2070 scenario sustainable yield, using only the change in storage,
estimated 2070
scenario loss of interconnected surface waters should be considered an undesirable result for
the Corning Subbasin unless beneficial uses and water availability analyses are done to
demonstrate that the management actions and the GSP cause no significant and
Trust resources. The GSP does cite a portion of the description of role of the sustainable yield
estimate in SGMA from the 2017 Sustainable Management Criteria Best Management
4
Practices, Section 4.4.6 (page 4-88, pdf 361). The following is the full text from the BMP
document with italics and underlines added:
Role of Sustainable Yield Estimates in SGMA
In general, the sustainable yield of a basin is the amount of groundwater that can be
withdrawn annually without causing undesirable results. Sustainable yield is
referenced in SGMA as part of the estimated basinwide water budget and as the
outcome of avoiding undesirable results.
4
https://water.ca.gov/-/media/DWR-Website/Web-Pages/Programs/Groundwater-Management/Sustainable-
Groundwater-Management/Best-Management-Practices-and-Guidance-Documents/Files/BMP-6-Sustainable-
Management-Criteria-DRAFT_ay_19.pdf
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sustainable yield be provided in the GSP (or in the coordination agreement for basins
with multiple GSPs). A single value of sustainable yield must be calculated basinwide.
This sustainable yield estimate can be helpful for estimating the projects and
programs needed to achieve sustainability.
SGMA does not incorporate sustainable yield estimates directly into sustainable
management criteria. Basinwide pumping within the sustainable yield estimate is
neither a measure of, nor proof of, sustainability. Sustainability under SGMA is only
demonstrated by avoiding undesirable results for the six sustainability indicators.
If this description of the role of the sustainable yield estimate in SGMA is followed, then the
loss of flows in interconnected surface waters should be accounted for in the yield estimate.
The Historical baseline water budget shows that the net stream gains are always positive for
each water year type, AquAlliance Exhibit 2-1A (row 23, columns C through J). Even the
Current scenario water years have positive net stream gains, although they are reduced from
the Historical baseline, also see Comment No. 7, AquAlliance Exhibit 3-1A (row 23, columns C
through J), whereas the net gains for the 2070 scenario are all negative, except for wet water
years when a positive 3,700 afy gain is estimated, a 93% reduction from the Historical
baseline of 50,900 afy for wet water years, AquAlliance Exhibit 2-1B (rows 23, 47 and 70,
columns C through J).
The estimate of the sustainable yield for the Corning Subbasin using only the storage
because it ignores the
undesirable result to interconnected surface waters. The definition of sustainable yield in
SGMA, WC 10721(w), requires that annual groundwater withdrawals do not cause an
undesirable result, that is one or more. All six of the sustainability indicators listed in WC
10721(x) need to be considered when estimating the volume of groundwater that can be
sustainably produced, that is, the sustainable yield.
The sustainable yield for the Corning Subbasin should be revised to account for impacts on
interconnected surface water flows and the other five sustainability indicators. If \[t\]he key to
demonstrating a basin is meeting its sustainability goal is by avoiding undesirable results
(page 33 in DWR, 2017, Sustainability BMPs footnote 3), then the GSP must prevent impacts
to interconnected surface waters and the other undesirable results.
Without an impact analyses, the Corning Subbasin sustainable yield must result in net stream
gains to interconnected surface water that are equal to or greater than the Historical baseline
at the start of SGMA. This may require a reduction in groundwater pumping from the
Historical baseline if other components of the water budget result in additional losses to
surface water flows or other undesirable results, see Comment No. 7. The multiple scenarios
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sirable results is achieved. The estimated groundwater
pumping from that iterative analysis would be the appropriate sustainable yield.
s in net stream gains with both the basin-wide
and the three itemized surface water body water budgets is that the 2070 scenario predicts
significant and unreasonable losses from interconnected surface waters which should be
considered an undesirable result, and a negative impact to the Public Trust. The Corning GSP
ntify or analyze the effects of the interconnected surface water loss on beneficial
uses, users, or the Public Trust. Without the beneficial uses and water availability analyses,
the management of the subbasin shouldinterconnected surface
waters sustainability indicator below levels of the Historical baseline, and, in fact, may need
to improve the conditions in the subbasin to correct the management problems that lead to
5
the SGMA high-priority status, which triggered the need to develop a GSP for the
Corning Subbasin.
10. The apparently arbitrary decisions used in setting the MT depths were discussed above in
Comment No. 1. A more appropriate method for establishing the MT depths to prevent
undesirable results is to use the historical data of changes in groundwater levels and
groundwater storage during periods of extended below-normal water years,( i.e., droughts).
The Corning GSP provides information on the groundwater water budgets for each type of
water year with the Historical baseline, Current, and Projected 2070 scenarios in Appendix 4D
Tables 4D-6, 4D-14, and 4D-34, respectively (appendices only file pdf 421, 429, and 449). The
cumulative change in groundwater storage for the Historical baseline is plotted in Figure 3-31
(page 3-75, pdf 224). The GSP do provide a plot of the other scenario cumulative change
in storage.
AquAlliance Exhibit 6 is a plot of the Current and Projected 2070 cumulative changes in
groundwater storage based on the groundwater model of the Corning Subbasin. A table is
included on the exhibit that lists values for the averages and three water year types for the
Historical baseline, Current, and 2070 scenario water budgets, see AquAlliance Exhibits 1, 2
and 3. Lines are drawn on top of the cumulative change graphs that estimate the slope of the
annual loss groundwater storage during droughts lasting 3 or more years. The estimated
annual loss in storage ranges from -34,375 afy to -57,600 afy. The estimated average annual
loss in groundwater storage for the 2070 scenario in CD/D water years falls within this range
at -41,800 afy, AquAlliance Exhibit 2-1B (row 45, column D).
The Corning GSP also provides information on the changes in groundwater level in the
subbasin from 2010 to 2015 on Figure 3-22 (page 3-55, pdf 204) and the change in
groundwater storage during this time in Table 4D-2 (appendices only file pdf 417), and in
Section 3.2.3 (pages 3-72 and 3-74, pdf 222 and 223). Using the average changes in
5
Corning Subbasin 5-021.51, high priority with 22.5 priority points, accessed 4.16.2022;
https://gis.water.ca.gov/app/bp-dashboard/final/
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groundwater levels and the cumulative change in groundwater storage from 2010 to 2015, an
estimate can be made of the basin-wide volume of groundwater yielded with each 1-foot
decline in groundwater level. The volume in acre-feet per foot (af/f) can then be used to
estimate a basin-wide average decline groundwater during consecutive years of drought.
AquAlliance Exhibit 7 provides several tables that list and calculate the average decline in
depth of groundwater from 2010 to 2015 taken from Figure 3-22 and sorted into the stable,
slight decline and declining sub-regions as shown on Figure 6-1 (page 6-12, pdf 421). The
decrease in groundwater levels from 2010 to 2015 ranged from -9.2 feet for the stable region
to -16.8 for the declining region, with a basin-wide average of -13.75 feet. Using this average
decline and the cumulative loss in groundwater storage of -114,600 af calculated from data in
Table 4D-2, a basin-wide average yield of 8,334 af/f is estimated. Using the 207,342 total
acres for the Corning Subbasin, Section 3.1.1 (page 3-1, pdf 150), an average specific yield of
approximately 4% is calculated for the shallow aquifer system.
If the acreage for the available groundwater is less than the full subbasin area, the specific
yield increases to approximately 5.56% and 8.33% for 150,000 and 100,000 acres of available
groundwater source area. Using the estimated basin-wide yield of 8,334 af/f, a calculation
can be made for the basin-wide average decline in groundwater level that would occur during
multiple CD/D water years, i.e., a drought, for both the Historical baseline and the 2070
scenario.
11. The sustainable management of groundwater as envisioned by SGMA likely requires that a
temporary groundwater storage surplus be maintained to meet the needs of users during
droughts and to protect the beneficial uses of streams, wildlife, and groundwater dependent
ecosystem (WC 10721(w)). That is, subbasin management actions should provide for storing
sufficient groundwater needed to counter the losses from a drought to protect and minimize
drought impacts to all beneficial uses and users, and the Public Trust.
If that is a
declining groundwater levels for a reasonable number of continuous years of drought after
adjusting for the temporary storage surplus created during normal, above normal, and wet
rather than the arbitrary method of the Corning GSP that set the depths far below the recent
historical maximum, which then results in several decades of continuous groundwater level
declines and loss in storage before an undesirable result needs to be declared?
The average annual Historical baseline change in groundwater storage for CD/D water years
is -27,450 afy, AquAlliance Exhibit 2-1A (row 21, column E). Using the 8,334 af/f basin-wide
yield and the Historic baseline change in annual storage, an average annual decline in
groundwater level of -3.29 ft is calculated, AquAlliance Exhibit 7. For a drought of 3
consecutive CD/D water years, a cumulative storage loss of -82,350 af would be accompanied
by a -9.9 ft decline in groundwater level. For 4 consecutive CD/D water years, the cumulative
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storage loss would be -109,800 af with a groundwater level decline of -13.2 ft. This estimated
decline in groundwater level is consistent with the 2010 -2015 decline of 13.75 ft.
If the change in groundwater storage for CD/D water years with the 2070 scenario
of -41,800 afy is used, the decline in groundwater would be approximately -5 feet per
drought year. For 3 consecutive 2070 scenario CD/D drought years, the decline would be -15
feet, and for 4 consecutive years the decline would be -20 feet. The -20 feet is consistent with
the Corning GSP setting the MT depth for the stable shallow aquifer zone at the \[m\]inimum
fall groundwater elevation since 2012 minus 20-foot buffer, AquAlliance Exhibit 1. In other
words, the MTs are apparently set to allow for 4 years of additional drought after
groundwater levels decline to the lowest fall groundwater elevation since 2012. Declaration
of an undesirable result wouldanother 2 years of continuous drought
-month exceedance requirement, or 6 years after the lowest historical
groundwater level is reached. The decline to the lowest elevation since 2012 may take one or
more years based on the elevation difference between the MOs and the 2012 low,
AquAlliance Exhibit 1-2. Therefore, the MTs appear to be set to allow for 7 years of
continuous drought at the 2070 scenario rate of storage loss. Setting the MT depths to trigger
an undesirable result in the lowering of groundwater level at 7+ years of drought is a
questionable management practice that will likely result in significant and unreasonable
impacts to shallow domestic wells and interconnected surface waters.
12. A more appropriate method for determining the MT depth would be to use the estimated
decline in groundwater levels from an extended period of drought, such as 3 years. The MTs
depths would be set at the depth below the MOs that accommodates the decline in
groundwater levels during this extended period of drought. From the discussion in Comment
No. 11, the MTs for 2070 scenario should be set at no deeper than 15 feet below the MO
elevations. The MT depth may need to be less to accommodate the 24 months of MT
exceedance requirement.
The GSP proposes that a declaration of an undesirable result can be made only after
groundwater levels decline below the MT depth and remain there for 24 continuous months.
If the MTs are set at 15 feet below the MOs, then a drought of 5 years could occur before an
undesirable result would be declared with possibly an additional 10 feet of groundwater
decline. This would result in 25 feet of groundwater level decline under the 2070 scenario
and a total storage loss of approximately 200,000 af (25 years X 8,334 af/f = 208,350 af),
which is not quite double the 114,600 af historical storage loss from 2010 to 2015,
AquAlliance Exhibit 7. This suggests that perhaps a more appropriate sustainable depth for
the MTs should be set at 5 feet below the MOs that allows only 1 year of drought storage
loss with the assumption that an additional 2 years of drought can occur before an
undesirable result is declared.
13. As discussed in Comment Nos. 6, 7 and 9, the 2070 scenario assumption that the Corning
Subbasin has a sustainable yield of 171,800 afy is inappropriate because this volume of
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pumping results in significant and unreasonable loss to interconnected surface waters, which
is a SGMA unreasonable result. The 2070 scenario CD/D water year pumping is estimated at
182,300 afy, which results in greater losses to stream flow than with the average annual 2070
production, AquAlliance Exhibit 2-1B (rows 44 and 47, columns C and E).
As discussed in Comment No. 9, the sustainable yield of the subbasin needs to be
recalculated based on beneficial uses and surface water availability analyses so that none of
the six SGMA undesirable results occur. Without the beneficial uses and water availability
analyses, the GSP should assume that the future pumping volumes are no greater than the
Historical baseline. The sustainable yield pumping may need to be less to accommodate
future climate changes, see Comment No. 7. With a reduction in sustainable yield pumping
volume, the annual loss in groundwater storage will likely be reduced. A reduction in CD/D
water year storage losses would require recalculation of the proper depth for the MTs below
the MOs, which would likely reduce the elevation difference between the MOs and MTs.
14. The Corning GSP identified salinity, nitrate, and arsenic as Contaminants of Concern (COC) for
the subbasin, Section 3.2.6.3 (page 3-94, pdf 243). The plan also identified the locations of
historical and current contaminant cleanup sites, Figures 3-37 through 3-40 and Table 3-8
(pages 3-86 through 3-90, pdf 235 through 239). The COC at the cleanup site include fuels,
solvents, herbicides, fumigants, and pesticides, Table 3-8. The GSP states that local, state,
and federal water quality standards applicable to the Subbasin need to be taken into
consideration when setting water quality sustainable management criteria (SMC), and that
ata
during GSP implementation and establish consistency with other programs, Section 6.8.2
(page 6-41, pdf 450).
Despite the occurrence of multiple COCs in the subbasin, the GSP will track as a sustainable
management criterion only one water quality COC, salinity, using Total Dissolved Solids (TDS)
concentrations. To track salinity, the GSP will rely on a RMP groundwater quality monitoring
well network of 15 wells, made up of 11 municipal wells in the City of Corning and Hamilton
City, and 4 small water supply wells, Section 5.4.1.6, and Figure 5-8 (page 5-27 and 5-28,
pdf 389 and 390). Tables 5-3 and 5-4 (pages 5-21 and 5-25, pdf 383 and 387) list public water
supply wells and groundwater quality network wells, but the 15 RMP network water quality
wells a in these tables, except in Figure 5-8, which has only general well
owner identifications. Therefore, the actual wells the GSP will use for the RMP water quality
monitoring network and location. A table is needed that lists
the RMP groundwater water quality wells names, well locations, well owners, screened
intervals, well types, water quality monitoring frequency, all the COC that will be monitored
at each well, the water quality standards for each COC, the monitoring and reporting
frequency, and the monitoring and reporting agency.
The SMC for groundwater quality requires that at least 25% of the 15 RMP network water
quality monitoring wells, i.e., 3 wells, must exceed the salinity MT for 2 consecutive years
Corning Sub-basin GSAPage 37
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where it is established that the GSP implementation is the cause of the exceedance to trigger
an undesirable resul t, Table ES-1, and Section 6.8.4.1 (page ES-22, 6-45 and 6-46, pdf 42, 455
and 456). The justification for requiring water quality exceedance in multiple wells for
multiple ye for the expansion of water quality degradation
before the Corning GSAs will act to prevent an undesirable result. Taking action to protect
water quality, especially for drinking water supplies,
until the problem gets widespread and pervasive. In addition, the requirement that someone
must
SGMA requirement to protect water quality.
The definition of unreasonable result for water quality degradation includes the migration of
contaminant plumes that impair water supplies, WC 10721(x)(4), even when the plumes
are caused by the GSAs implementation of the GSP.
The sustainability
standard directs the GSAs to prevent the spread of the contaminant(s), regardless of who is
to blame for the plume or water quality degradation. Actions by the GSAs should need to
wait for long-term exceedance of a water quality standard at multiple wells across a large
portion of the subbasin before actions are taken to mitigate the impact. In addition,
groundwater management actions should prevent the migration of contaminant plumes into
the Corning Subbasin from adjacent subbasins.
The GSP should describe future management actions that will be taken to prevent the spread
of contaminants even before they exceed the water quality standards at one or more of the
RMP network wells, and at the other water quality monitoring wells in the Corning Subbasin
and adjacent subbasins. The GSP should also address how the Well Mitigation Program will
assist domestic wells owners whose wells have become polluted. Assistance such as well
head testing and treatment should be part of the Corning GSPs water quality mitigation
program.
Although the Corning GSP calls for coordination in management of water quality with other
governmental agencies, are the MOs or MTs for all the
potential contaminants of concern in the Corning Subbasin, or what GSP management
actions will be taken whenever a water quality impact is identified by these coordinating
agencies.
What is the role of the GSAs in protecting water quality for all beneficial uses and users? In
particular, the protection of domestic water supply must be the primary concern for
managing the subbasin, WC 106.3(a). SGMA empowers the GSAs with the authority to control
pumping rates and locations throughout the subbasin to protect all beneficial uses and users
of groundwater, an authority over groundwater resources that other regulatory agencies
xecutive Order N-7-
22.
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The Corning GSP should provide a concise description of what projects and management
actions the GSAs will be taking to prevent degradation of the subbasin water quality for all
potential COCs, describe how the GSAs will remedy in a timely manner any water quality
degradation that occurs, and develop a Well Mitigation Program that is fully funded and
provides for meaningful assistance to impacted well owners with repair, treatment, and/or
well replacement.
15. The Corning GSP sets the MO at zero feet for inelastic subsidence solely due to lowered
groundwater elevations throughout the subbasin, in addition to any measurement error,
Section 6.9.3 (page 6-55, pdf 464). If the InSAR dataset is used with its measurement error of
0.1 ft, then annual subsidence of 0.1 ft or less would not be considered measurable inelastic
subsidence.
The MT rate for inelastic subsidence is 0.50 ft over 5 years, Table ES-1 and Sections 6.9.2
(pages 6-48, pdf 457). Although the Corning Subbasin has experienced little to no historical
inelastic subsidence since the start of monitoring in 2004 (page 6-48, pdf 457), the MT was
to maintain consistency with neighboring subbasins, Section 6.9.2.3 (pages 6-55 and 6-
54, pdf 462 and 463). The neighboring subbasin to the south, Colusa Subbasin, has historically
experienced inelastic subsidence and the MT for subsidence for that subbasin is also 0.5 feet
over 5 years. Figure 6-11 shows the InSAR land subsidence data for the area at the southern
border between the two subbasins surrounding Orland and Hamilton City (page 6-49, pdf
458). A north-south oriented area of subsidence ranging from -0.25 to -0.75 feet occurs just
south of Orland. The Corning GSP indicates that groundwater pumping in the Colusa Subbasin
near Orlan the potential to impact the ability of the Corning Subbasin GSAs to meet the
subsidence minimum thresholds-54, pdf 463). Apparently, to be consistent with a
se the
same MT, .
The Corning an MT that allows
northward expansion of the Colusa Subbasin subsidence is beneficial to the infrastructure
and landowners in the Corning Subbasin.
historical long-term subsidence in the Subbasin, and if this in the future, then
beneficial users and land uses should not be impacted by the subsidence minimum threshold,
Section 6.9.2.4 (page 6-54, pdf 463).
While it is probably true that if the Corning Subbasin continues to have little or no inelastic
subsidence, the MT value will have no effect. However, it might not be true if subsidence
begins the 0.50
ft over 5 years MT subsidence rate is a reasonable standard
experience inelastic subsidence. The logic of the Corning GSP in setting the MT the same as
the Colusa GSP seems to be that if they are okay with this amount of subsidence, then we
should be okay too. No actual assessment of the impacts of this level of subsidence on the
infrastructures in the Corning Subbasin are proposed in the GSP.
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The Corning GSP takes the approach that:
The undesirable result for subsidence allows for no more than 0.5 foot of cumulative
subsidence in the Subbasin during a 5-year period. This amount of subsidence is not likely
to impact beneficial users and land uses such as highways, canals, and pipelines as it is
about equal to the total subsidence in one portion of the Subbasin and no impacts to
infrastructure have been reported to date. No other beneficial users or land uses are
anticipated to be impacted by subsidence in the Subbasin. Section 6.9.4.3 (page 6-57, pdf
466)
This technical standard
needs some technical justification. The Corning GSP should be revised to provide specific
information on the critical infrastructure in the Subbasin that includes: a description of the
structures, the entities responsible for maintenance, how much subsidence these structures
can tolerate without structural damage, the linkage and/or interdependence of these
structures, the alternatives should a structure fail, the estimated costs for repairing structural
damage, and the frequency of structural inspections, etc.
In addition to evaluating critical infrastructure, the GSP should address how small areas of
subsidence, such as sinkholes, will be managed. Sinkholes, peat decomposition, and natural
settlement can all be triggered by declining groundwater levels. The GSP appears to require
proof that settlement or subsidence is due to groundwater pumping, Section 6.9 (page 6-47,
, in
particular, and affects only a few private
structures, like homes. The GSP seems to say that the landowner is responsible for
demonstrating to the GSAs that the cause of any local settlement is groundwater decline due
to pumping. Even if the landowner was able to prove the cause was declining groundwater
propose any mitigation program to assist in making
structural repairs.
Lastly, the Plan fails to disclose the numerous sinkholes within and just outside the subbasin.
The sinkholes were widely discussed by local and state government from August 2021
67
forward, allowing time to insert this information in the draft and final GSPs. This serious
omission adds to the conclusion that the Corning GSP and GSAs are not ready to take on the
task of managing the subbasin.
6
Massa, Rick August 16, 2021 e-
7
"Ms. Hunter also stated that staff was made aware of sink holes developing in the Colusa and Corning subbasins,
and that a site visit has been conducted with Department of Water Resources." Glenn Groundwater Authority
December 14, 2021 minutes p. 2 (packet pdf p. 8).
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Conclusion
For all the reasons discussed in our comments on the Corning Subbasin here, the Plan fails to
beneficial users and uses. In accordance with legal requirements to protect the Public Trust, the
Plan also fails. It also appears that the GSP will foist the responsibility to demonstrate damage
from undesirable results on the unsuspecting public, creating an impossible burden for all but the
large water districts with deep pockets. The Plan must be rejected by DWR and the SWRB.
Respectfully submitted,
Bill Jennings, Chairman
Barbara Vlamis, Executive
Carolee Krieger, President
California Sportfishing
Director
California Water Impact
Protection Alliance
AquAlliance
Network
3536 Rainier Avenue
P.O. Box 4024
808 Romero Canyon Road
Stockton, CA 95204
Chico, CA 95927
Santa Barbara, CA 93108
(209) 464-5067
(530) 895-9420
(805) 969-0824
deltakeep@me.com
barbarav@aqualliance.net
caroleekrieger@cox.net
Jim Brobeck
Water Policy Analyst
AquAlliance
jimb@aqualliance.net
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10000StockdaleHighway,Suite200,Bakersfield,CA93311
p.6613951000f.6613260418 ǞǞǞ͵ƉƌĻźƓƌğǞ͵ĭƚƒ
April 22, 2022
Paul Gosselin
Department of Water Resources
901 P Street Room 213
Sacramento, CA 94236
Re: Comments to the GSP for the Corning Groundwater Basin
Dear Mr. Gosselin:
The purpose of this letter is to provide the Department of Water Resources (DWR) with
the comments of Farmland Reserve, Inc. (as the landowner) and Deseret Farms of California (as
the operator) to Tehama County Flood Control & Water Conservation District Groundwater
Sustainability Agency and Corning Subbasin Groundwater Sustainability
sustainability plan (GSP). Provided are those comments:
1. The GSAs should refine Figures 6-1 and 6-2
Section 6.6 of the Sustainable Management Criteria (SMC) chapter, regarding the
Chronic Lowering of Groundwater Levels identifies three general zones with distinct
groundwater level trends. (see GSP, Section 6.6.
three general zones, as illustrated in Figures 6-1 and 6-2, demonstrates the variability of
groundwater conditions across the Subbasin using oval shapes
demonstrates the area within the Subbasin in which groundwater levels are declining the most.
ea within the Subbasin in which groundwater
levels are only slightly declining. And finally, demonstrates the area
within the Subbasin in which groundwater leve
ree general zones. This overlap could result
in unclear or incorrect data and therefore affect the
Subbasin and the unique characteristics of each general zone. To avoid this issue, the GSAs
should refine Figures 6-1 and 6-
better define areas related to selected
representative monitoring points (RMP). It will also help to avoid overlap of information, and
tie in land and aquifer characteristics based on established RMPs. Vina Groundwater
of how this approach can be used successfully. There, Vina GSA created management areas
Klein, DeNatale, Goldner, Cooper, Rosenlieb, & Kimball, LLP
Bakersfield|Fresno|SanDiego|SantaBarbara
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by dividing the subbasin into specific polygons. Each polygon, being different in shape and
size, was determined by the distribution of the representative monitoring site wells in the area.
Vina GSA found that its use of this approach resulted in a more refined data set for use in its
GSP. Therefore, we recommend that the GSAs refine Figures
nd use of this approach.
We raised this concern to the GSAs; however, their response quickly dismissed our
comment, stating that:
The three groundwater level trends do not provide a specific
boundary for each trend and were not indented to be used as
management areas. The generalized zones are for visual
representation only.
The GSAs concern regarding a lack of specific boundaries could be easily addressed
overlap and create those specific boundaries sought after by the GSAs. Further, while the GSAs
claim that these general zones were created for
matter is that each general zone depicts a unique area of the Subbasin with unique groundwater
characteristics, thereby creating the beginnings of three separate management areas.
2. The GSAs should establish three management areas using those newly established
polygons.
Currently, the GSAs have not established management areas within the Subbasin.
(GSP, Section 6.4 (Pg. 6-6).) Notably, however, eserve the right to
Ibid.)
As noted above, the GSAs have already identified significant differences in three areas
within the Subbasin. Accordingly, we do not believe that the GSAs should subject the entire
Subbasin and its stakeholders to the same management practices. Instead, we believe that
management areas are necessary, and therefore recommend that the GSAs establish these areas
to reflect the polygons discussed above, once established.
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3. The GSAs should revise the Measurable Objectives and the Minimum Thresholds.
The GSP establishes Measurable Objectives (MO) and Minimum Thresholds (MT) for
each SMC beyond what is required to achieve the
For example, the MTs for the Chronic Lowering of Groundwater SMC are set as follows:
For wells that had recent historical (between 2010 and 2019)
stable groundwater elevations (stable wells): Minimum fall
groundwater elevation since 2012 minus 20-foot buffer.
For wells that had recent historical (between 2010 and 2019)
declining groundwater elevations (declining wells): Minimum
fall groundwater elevation since 2012 minus 20% of minimum
groundwater level depth.
(GSP, Section 6.6.2 (Pg. 6-8).)
These MTs provide little to no operational flexibility to landowners within the
Subbasin. Instead, these MTs make it harder for landowners to operate their respective farms
and ranches while working towards the sustainability goal of the Subbasin. The GSAs should
look towards their neighbors, Red Bluff Subbasin GSA and Antelope Subbasin GSA, to
consider potential revisions to the MTs.
drastic MTs. Both GSAs have set the MTs for the Chronic Lowering of Groundwater SMC as
follows:
Upper Aquifer: Spring groundwater elevation where less than 10
- 20% (on average) of domestic wells could potentially be
impacted.
Lower Aquifer: Spring groundwater elevation minus 20 to 120
feet.
(see Red Bluff Subbasin GSA GSP, Section 3.3.1.1 (Pg. 3-19); see also Antelope Subbasin
GSA GSP, Section 3.3.1.1 (Pg. 3-17).)
within the Subbasin would have the flexibility needed to realistically and timely achieve the
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purpose of the MTs, while allowing for flexibility to weather the next 20 years and beyond. In
addition, such revisions would continue to be cognitive of domestic well concerns.
Please feel free to contact us if you have any questions or wish to discuss any of our
comments.
Very truly yours,
Joseph D. Hughes
JDH:AND
cc: Farmland Reserve, Inc.
Deseret Farms of California
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STATE OF CALIFORNIA – CALIFORNIA NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CENTRAL VALLEY FLOOD PROTECTION BOARD
3310 El Camino Ave., Ste. 170
SACRAMENTO, CA 95821
(916) 574-0609 FAX: (916) 574-0682
April 22, 2022
Paul Gosselin, Deputy Director
Statewide Groundwater Management
California Department of Water Resources
th
1416 9 Street
Sacramento, CA 95814
Lisa Hunter, Plan Manager
County of Glenn GSA - Corning
225 North Tehama Street
Willows, CA 95988
Subject: Comments on Corning Subbasin Groundwater Sustainability Plan
Dear Mr. Gosselinand Ms. Hunter,
Thank you for the opportunity to comment on the Corning Subbasin Groundwater Sustainability
Plan (GSP), which is a joint document prepared by two Groundwater Sustainability Agencies
1
(GSAs). The GSP describes how the GSAs will reach long term groundwater sustainability by
outlining the need to reduce overdraft conditions and by identifying projects that may replace or
supplement groundwater supplies to meet current and future water demands.
The Central Valley Flood Protection Board (Board) is the State’s regulatory agency responsible
for ensuring appropriate standards are met for the construction, maintenance, and operation of
the flood control system that protects life, property, and habitat in California’s Central Valley.
The Board serves as the State coordinator between the local flood management agencies, and
the federal government, with the goal of providing the highest level of flood protection possible
to California’s Central Valley.
Encroachment Permit
As required by California Code of Regulations, Title 23, Division 1 (Title 23), Section 6,
approval by the Board is required for all proposed encroachments within a floodway, on
adjacent levees, and within any Regulated Stream identified in Title 23, Table 8.1. Specifically,
Board jurisdiction includes the levee section, the waterward area between project levees, a
minimum 10-foot-wide strip adjacent to the landward levee toe, the area within 30 feet from the
top of bank(s) of Regulated Streams, and inside Board’s Designated Floodways. Activities
1
The Corning Subbasin GSP was prepared by the following GSAs: Corning Sub-basin GSA and the Tehama
County Flood Control and Water Conservation District.
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Page 2 of 3
outside of these limits which could adversely affect Federal-State flood control facilities, as
determined by Board staff, are also under Board’s jurisdiction. Permits may also be required for
existing unpermitted encroachments or where it is necessary to establish the conditions
normally imposed by permitting, including where responsibility for the encroachment has not
been clearly established or ownership or uses have been changed.
Some of the proposed projects identified in the GSP are within the Board’s jurisdiction, thereby
requiring Board approval. These projects include, but are not limited to,the levee setback and
stream channel restoration projects. Please alert Board staff if you would like to schedule a
pre-application meeting to discuss any of the projects in detail and/or to determine the
documentation required to process an encroachment permit.
Federal permits, including U.S. Army Corps of Engineers (USACE) Section 404 and Section 10
regulatory permits and Section 408 Permission, in conjunction with a Board permit, may be
required for the proposed projects. In addition to federal permits, state and local agency
permits, certification, or approvals may also be required. State approvals may include, but are
not limited to, California Department of Fish and Wildlife’s Lake and Streamed Alteration
Agreement and Regional Water Quality Control Board’s Section 401 Water Quality
Certification. The project proponent must obtain these authorizations.
Closing
The Board recognizes the importance of groundwater sustainability in California and
commends the GSAs on their effort in planning for a more resilient future. However, the
potential risks to public safety, including increased flood risks, need to be considered when
developing proposed projects that seek to mitigate for unsustainable groundwater extraction.
The Board seeks to establish a collaborative approach with GSAs to better fulfill our regulatory
responsibilities in the new paradigm of SGMA. Board staff is available to discuss any project(s)
proposed under the GSP as it relates to flood control works.
If you have any questions regarding these comments, please contact Ruth Darling at
(916) 574-1417, or via email at Ruth.Darling@cvflood.ca.gov.
Sincerely,
Ruth Darling, Program Manager
Flood Planning and Programs Branch
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ec:Lisa Hunter, Plan Manager
lhunter@countyofglenn.net
Paul Gosselin, Deputy Director
Paul.Gosselin@water.ca.gov
Portal Submission: https://sgma.water.ca.gov/portal/gsp/comments/94
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Public Comments Received After the Public Comment Period
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Re: Corning subbasin
Groundwater Sustainability Plan
managing, conserving, and protecting living marine resources in inland, coastal, and offshore
waters of the United States. We derive our mandates from numerous statutes, including the Federal
Endangered Species Act (ESA). The purpose of the ESA is to conserve threatened and endangered
species and their ecosystems.
Surface water and groundwater are hydraulically linked in the Corning subbasin. Several
waterways that overlie portions of the Corning subbasin support federally threatened California
Central Valley (CCV) steelhead (Oncorhynchus mykiss), threatened Central Valley (CV) spring-
run Chinook salmon (O. tshawytscha), the threatened Southern Distinct Population Segment
(sDPS) of North American green sturgeon (Acipenser medirostris), and federally endangered
Sacramento River winter-run Chinook salmon (O. tshawytscha). In addition, the Corning subbasin
is designated as Essential Fish Habitat (EFH) for Pacific Coast Chinook salmon, including CV fall-
run Chinook salmon and CV late fall-run Chinook, which are managed under the MSA. Where the
groundwater aquifer supplements streamflow, the influx of cold, clean water is critically important
for maintaining temperature and flow volume. Pumping water from these aquifer-stream
complexes is likely affecting salmon and steelhead habitat by lowering groundwater levels and
interrupting the hyporheic flow between the aquifer and stream.
General Comments
1) The Final GSP does not adequately address the following requirement for minimum thresholds
as defined in the SGMA regulations:
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
The GSA has not explained how the proposed minimum thresholds for streamflow depletion
(i.e., groundwater levels lower than the minimum levels seen since 2012) avoids significant and
unreasonable impacts to beneficial uses of surface water. Surface water beneficial uses are not
described or characterized in the GSP, nor is the ability of the proposed sustainable
management criteria to avoid impacting those uses analyzed. We maintain that groundwater
and ssustainable management
criteria would mirror extreme drought conditions, and are very likely to harm ESA-listed
salmonids and degrade their designated critical habitat. As we have noted in our prior
comment letter to the Corning GSA, surface water beneficial uses for the Corning surface
waters include cold freshwater habitat; migration of aquatic organisms; and spawning,
1
reproduction, and/or early development of aquatic organisms.
1
Central Valley Regional Water Quality Control Board Basin Plan. Copy available at:
https://www.waterboards.ca.gov/centralvalley/water_issues/basin_plans/#basinplans
1
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GSP Regulations require that the description of minimum thresholds include how minimum
thresholds may affect the interests of beneficial uses and users of groundwater or land uses and
property interests, and that the description of undesirable results must include 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. The GSP does not
adequately address these requirements. Furthermore,
reasonable analysis of the groundwater conditions and the associated effects the GSAs must
quantitative sustainable management criteria to prevent those undesirable conditions from
2
The GSP does not appear to include any description or analysis of the effects
associated with interconnected surface water depletion that the plan is attempting to avoid.
Finally, the measurable objective (i.e., maximum fall groundwater elevation since 2012 or
maximum fall groundwater elevation in 2015) does not define specific significant and
unreasonable effects constituting the interconnected surface water depletion undesirable result,
a result of applying the groundwater storage measurable objective without appropriately
considering impacts to surface water beneficial uses.
2) We remain concerned the chosen sustainable management criteria for the streamflow
depletion undesirable result are inappropriate for avoiding significant impacts to ESA-listed
salmonids and their habitat. Groundwater flow to a stream, or conversely seepage from a
stream to the underlying aquifer, is proportional to the difference between water elevation in
the stream and groundwater elevations at locations away from the stream. Simply stated, the
minimum threshold likely creates groundwater conditions (and streamflow depletion impacts)
consistent with severe drought. In fact, the established sustainable management criteria would
historic drought. These conditions significantly impacted aquatic resources throughout the
state (CDFW 2019), and thus would be very likely to adversely affect CV steelhead and CV
spring-run Chinook salmon, as well as their designated critical habitat. Furthermore, per
f exceeded,
chosen minimum thresholds do not represent a point at which those effects may arise, as is
required, but instead represent a likely impact level far past that point. Finally, SGMA
stated above, we do not believe the GSP has justified how the chosen sustainability indicator
for streamflow depletion relates to federal standards under the ESA, namely avoiding unlawful
take of ESA-listed species.
3) The trigger for the streamflow depletion undesirable result occurs when 20% of groundwater
elevations measured at RMP wells drop below the associated minimum threshold during 2
consecutive years. (page ES-22). The GSP does not justify or discuss how the 20 percent
threshold was developed, or how that threshold informs the onset of significant and
unreasonable impacts to beneficial uses of surface water. Moreover, the undesirable result
reasons that exceeding the minimum thresholds during dry years is not an undesirable result if
However, this provision applies
2
DWR Groundwater Sustainability Plan Assessment for the Eastern San Joaquin subbasin. Copy available at:
https://sgma.water.ca.gov/portal/gsp/assessments/47
2
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to depletion of groundwater storage, and was not intended to be expanded to other undesirable
results. Finally, aquatic organisms persist or perish based upon the impacts to aquatic habitat
occurring at a moment in time. In essence, the current definition would allow severe impacts to
surface water beneficial uses and ESA-listed species during one year, but an undesirable result
would not arise unless a second year of impacts followed the first. Requiring two consecutive
years of minimum threshold violations makes little ecological sense when trying to monitor and
address impacts to surface water beneficial uses and groundwater dependent ecosystems caused
by groundwater pumping.
4) When developing sustainable management criteria, and projects and management actions, the
GSP appears to be missing adequate analysis and consideration of public trust resources, as
3
required by the Public Trust Doctrine. A recent California Court of Appeal decision held that
the public trust doctrine must be consideredand public trust resources protected whenever
feasiblein any decision governing groundwater withdrawals hydrologically connected to
public trust surface waters. Concerning public trust resources, the GSP states the following:
The various beneficial uses and users of surface waters were addressed when
setting the interconnected surface water depletion minimum thresholds including
riparian rights holders, ecological surface water users, and recreational surface
water users. This is a reasonable review of all uses and users in an attempt to
balance all interests. This is not an assessment about what constitutes a reasonable
beneficial use under Article X, Section 2 of the California Constitution.
As noted above, CV steelhead and CV Chinook salmon, listed as threatened under the federal
Endangered Species Act, inhabit many of the navigable waterways overlying the Corning
subbasin, and should clearly be considered a public trust resource. Moreover, many of these
4
streams and rivers clearly meet the definition of public trust surface waters. We reiterate our
view that streamflow conditions associated with the chosen sustainability criteria are very
likely to impair or preclude salmon and steelhead migration, rearing, and spawning habitat, and
thus harm public trust resources. Thus, the assertion that providing full historical groundwater
extraction while likely harming ESA-
In short, the GSP does not appear to conduct an
appropriate public trust analysis, nor does it even discuss what ecological public trust resources
are applicable to the subbasin. Likewise, no weighing of public trust benefits or impacts occurs
within the GSP. Lastly, the GSP fails to adequately consider and evaluate alternative measures
that would likely protect ecological public trust resources, such as the feasibility of adopting
more conservative sustainable management criteria that will avoid harming NA green sturgeon,
CV steelhead, CV Chinook salmon, and their designated critical habitat.
Essential Fish Habitat
NMFS is the lead federal agency responsible for the stewardship of the nation's offshore living
3
Environmental Law Foundation v. State Water Resources Control Board (2018) 26 Cal.App.5th 844
4
The public trust applies to navigable water bodies, as well as non-navigable water bodies where the harm to such
water bodies manifests itself downstream to a navigable water body. See ELF v. SWRCB (2018)
3
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marine resources and their habitats, and implements the ESA and the Magnuson Stevens Fishery
Conservation and Management Act (MSA) to fulfill its mission of promoting healthy ecosystems.
Federally-managed living marine resources provide an important source of food and recreation for
the nation, as well as thousands of jobs and a traditional way of life for many coastal communities.
For the purposes of the MSA, EFH means "those waters and substrate necessary to fish for
spawning, breeding, feeding, or growth to maturity", and includes the associated physical,
chemical, and biological properties that are used by fish (50 CFR 600.10).
EFH has been designated within the GSP area by the Pacific Fishery Management Council (PFMC)
for the Pacific Coast Salmon Federal Fishery Management Plan (PFMC 2016). Waterways
overlying the Corning subbasin contain EFH for the Pacific Coast Salmon FMP. Given the high
likelihood that managing groundwater elevations consistent with historically low drought levels
will continue to negatively affect listed species viability and generally degrade the greater
ecosystem (see comments #1 and #2 above). Implementing these conservation recommendations
would minimize the adverse and unreasonable effects to EFH and fulfill the obligations under
Section 305(b) of the MSA.
1. The GSP should be revised to incorporate more conservative sustainability management
criteria for the streamflow depletion undesirable result to avoid likely adversely affecting
ESA-listed salmonids and their critical habitat within the Corning subbasin. This
recommendation is especially critical given the admitted lack of appropriate data and
analysis throughout the subbasin concerning streamflow depletion impacts on salmonid
populations and their habitat.
This recommendation fulfills our obligation to provide EFH conservation recommendations to the
State as required by MSA Section 305(b)(4)(A). Please let us know how we can assist DWR in
addressing this issue.
Conclusion
Given the significant shortcomings outlined in this letter, we recommend DWR find the Corning
subbasin GSP insufficient at this time until those shortcomings can be rectified. Please direct
questions regarding this letter to Amanda Cranford, of my staff, at Amanda.Cranford@noaa.gov or
(916) 930-3706.
Literature Cited
Department of Fish and Wildlife. 2019. Statewide Drought Response: Stressor Monitoring
Summary Report: 2014-2017. Copy available at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=174241
4
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9. Corning Subbasin Advisory Board Report
The Corning Subbasin Advisory Board (CSAB) met on April 6, 2022. The CSAB received a
presentation by Montgomery & Associates providing an overview of the Water Year 2021
Corning Subbasin Annual Report, which was discussed at the April 13, 2022 CSGSA
meeting. The next CSAB meeting is scheduled for June 8, 2022 at 1:30 p.m.
CSAB meeting materials, including presentations, agendas, and meeting summaries are
available on the website at: www.corningsubbasingsp.org.
Advisory Board members may provide additional updates.
10. Discussion on Executive Order N-7-22
a. *Approve Well Permit Acknowledgement Form and authorize staff to finalize
process with the Glenn County Environmental Health Department
On March 28, 2022, Governor Newsom issued Executive Order N-7-22 which included well
permitting requirements during this drought emergency (Action 9). DWR shared a Fact
Sheet on April 5 to help agencies navigate the new requirements and outlined DWR
resources that may be useful.
The CSGSA discussed the Executive Order on April 13, 2022. A suggestion was made to
utilize the Acknowledgment Form, consistent with the Glenn Groundwater Authority, to be
compliant with the Executive Order. This form, or a similar form is being utilized by several
GSAs in the region.
The Glenn County Environmental Health Department is the local permitting agency. If
desired, staff could work with the Environmental Health Department to determine a
mutually agreeable process to communicate regarding well permitting, review of
applications, and compliance with the Executive Order.
Additional discussion may take place on other options to best address this new
requirement.
Attachments:
Executive Order N-7-22
DWR Fact Sheet: Drought Well Permitting Requirements
Well Permit Acknowledgement Form
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Updated: April 4, 2022
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within a given county.
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Hspvoexbufs!Tvtubjobcjmjuz!Bhfodz!
nbobhjoh!uif!cbtjo!ps!bsfb!pg!uif!cbtjo!
With the enactment of the Sustainable
xifsf!uif!xfmm!jt!qspqptfe!up!cf!mpdbufe!uibu!
Groundwater Management Act (SGMA) in
hspvoexbufs!fyusbdujpo!cz!uif!qspqptfe!xfmm!
2014, local public agencies called
xpvme!opu!cf!jodpotjtufou!xjui!boz!
tvtubjobcmf!hspvoexbufs!nbobhfnfou!
groundwater sustainability agencies or GSAs
qsphsbn!ftubcmjtife!jo!boz!bqqmjdbcmf!
formed to provide specific oversight and
Hspvoexbufs!Tvtubjobcjmjuz!Qmbo!bepqufe!cz!
management of groundwater resources, and to
uibu!Hspvoexbufs!Tvtubjobcjmjuz!Bhfodz!boe!
achieve sustainable groundwater management
xpvme!opu!efdsfbtf!uif!mjlfmjippe!pg!
bdijfwjoh!b!tvtubjobcjmjuz!hpbm!gps!uif!cbtjo!
within 20 years through the development and
dpwfsfe!cz!tvdi!b!qmbo<!ps!!
implementation of groundwater sustainability
!
plans (GSPs) and associated projects and
c/!Jttvf!b!qfsnju!gps!b!ofx!hspvoexbufs!xfmm!
ps!gps!bmufsbujpo!pg!bo!fyjtujoh!xfmm!xjuipvu!gjstu!
management actions. The local GSAs are
efufsnjojoh!uibu!fyusbdujpo!pg!hspvoexbufs!
required to include in their GSPs a discussion
gspn!uif!qspqptfe!xfmm!jt!)2*!opu!mjlfmz!up!
of how they will coordinate these efforts with
joufsgfsf!xjui!uif!qspevdujpo!boe!gvodujpojoh!
local land use authorities, including local well
pg!fyjtujoh!ofbscz!xfmmt-!boe!)3*!opu!mjlfmz!up!
dbvtf!tvctjefodf!uibu!xpvme!bewfstfmz!
permitting agencies.
jnqbdu!ps!ebnbhf!ofbscz!jogsbtusvduvsf/!!
!
Drought Well Permitting Requirements
Uijt!qbsbhsbqi!tibmm!opu!bqqmz!up!qfsnjut!gps!
Local well ordinances authorize the conditions
xfmmt!uibu!xjmm!qspwjef!mftt!uibo!uxp!bdsf.gffu!
for agencies to issue a well permit or permit
qfs!zfbs!pg!hspvoexbufs!gps!joejwjevbm!
epnftujd!vtfst-!ps!uibu!xjmm!fydmvtjwfmz!
modification. Given the record drought
qspwjef!hspvoexbufs!up!qvcmjd!xbufs!tvqqmz!
conditions the state has faced over the last
tztufnt!bt!efgjofe!jo!tfdujpo!227386!pg!uif!
three years, Drought Executive Order N-7-22
Ifbmui!boe!Tbgfuz!Dpef/!
requires additional actions be taken by local
well permitting agencies prior to issuing a well
permit.
For more information about the States Drought Response and Assistance, please visit drought.ca.gov.
Corning Sub-basin GSAPage 102
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Page Ћ of Ћ
Local well permitting agencies retain existing well permitting authorities, including reviewing and
administering well permits. Under the Executive Order Action 9, local well permitting agencies
must take the following steps during the well permitting process for wells intending to extract
groundwater:
1. Consultation with the GSA If the proposed well would be in a high or medium priority
groundwater basin, the well permitting agency must consult with the GSA and receive
written verification from the GSA that the proposed well location is generally consistent
(not inconsistent) with the applicable GSP and will not decrease the likelihood of
achieving the sustainability goals that the GSAs have developed under SGMA.
2. Permit Evaluation For every well permit application, the local well permitting agency
must determine before issuing a well permit that extraction of groundwater from the
proposed well is not likely to interfere with the production and functioning of existing
nearby wells and is not likely to cause subsidence that would adversely impact or
damage nearby infrastructure.
These requirements do not apply to wells that pump less than 2 acre-feet per year (de minimus
users) and wells that exclusively provide groundwater to public water supply systems as defined
in section 116275 of the Health and Safety Code.
State Resources Available to Local Agencies
The California Department of Water Resources (DWR) provides technical and other support
services to local agencies to support decision-making. The following resources are available to
help local agencies navigate the well permitting requirements in this Drought Executive Order:
To find the hspvoexbufs!cbtjot!tvckfdu!up!THNB and classified as medium or high
priority: Basin Prioritization Dashboard
To find the Hspvoexbufs!Tvtubjobcjmjuz!Bhfodz managing the applicable basin or area
of the basin: GSA Map Viewer
To find the Hspvoexbufs!Tvtubjobcjmjuz!Qmbo adopted by the local Groundwater
Sustainability Agency: GSP Map Viewer
To view fyjtujoh!ofbscz!xfmmt (domestic, irrigation, public supply and reported dry
wells): Well Infrastructure
To view hspvoexbufs!mfwfmt!boe!usfoet: California Groundwater
Levels
To view tvctjefodf!ebub!and nearby infrastructure: California
Subsidence Data
For more information or questions, please contact DWRs Sustainable Groundwater
Management Office at: SGMPS@water.ca.gov.
For more information about the States Drought Response and Assistance, please visit drought.ca.gov.
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CORNING SUB-BASIN GROUNDWATER SUSTAINABILITY AGENCY
COMPLIANCE WITH EXECUTIVE ORDER N-7-22
Pursuant to Executive Order N-7-22, the Corning Sub-basin Groundwater Sustainability Agency (CSGSA)
provides the following acknowledgment, which if executed by a well applicant, would allow the CSGSA
to conclude that the well permit would not be inconsistent with the existing groundwater sustainability
plan.
ACKNOWLEDGMENT
_____ I acknowledge that the Sustainable Groundwater Management Act requires that a groundwater
sustainability agency manage groundwater in the Corning Subbasin and the CSGSA is the agency with
groundwater management authority over the land subject to Permit # xxx.
______ I acknowledge that the CSGSA has the authority to limit, regulate and/or suspend extractions
within its jurisdiction including extractions from any well permitted pursuant to Permit #XXXX.
______I acknowledge that a well permit issued by the County does not guarantee the extraction of any
specific amount of water now or in the future.
_____ I acknowledge that the Corning Subbasin GSP includes specific groundwater requirements
through minimum thresholds and measurable objectives and agree that my groundwater use will
comply with these requirements.
_____ I acknowledge the CSGSA cannot guarantee the maintenance of any defined water level or level
of water quality in the Corning Subbasin.
___ I acknowledge the CSGSA is not responsible for or otherwise liable for any costs, investments or
payments related to any groundwater well permitted pursuant to Permit #xxxx, including pumping fees,
extraction limits, costs related to well failure, well deepening, increased maintenance, replacement, or
operational costs.
___I agree to hold the CSGSA harmless and indemnify the CSGSA for any liability stemming from or
related to the County issuing a well Permit #xxxx, any use restrictions imposed upon such well, and from
any claim or cause of action alleged against the CSGSA relating to or resulting from the use or operation
of such well.
By acknowledging and initialing the above provisions, \[WELL APPLICANT\] agrees the above
ACKNOWLEDGMENT will be incorporated into the terms and conditions of any well permit issued
pursuant to Permit #xxxx.
________________________ ___________________
Name of WELL APPLICANT Date
________________________
Signature of WELL APPLICANT
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Received by:
___________________ _____________
Signature of CSGSA Date
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11. Corning Sub-basin GSA 2022/2023 Budget
a. Discuss Short Term Funding Strategy
b. Provide direction on a proposed agreement among member agencies to fund
specific tasks or explore other potential options to meet short term funding needs
Over the past several months the CSGSA has discussed funding needs for GSP
Implementation. At the April 13, 2022 meeting, the CSGSA requested figures for
immediate short-term funding needs and longer term needs, breaking the discussion into
two parts. The short-term funding strategy will address immediate needs to provide for
GSA administration and prioritized tasks. The longer term needs will be discussed during
Item 12.
If a funding mechanism is prepared and finalized by August 10, 2022, the fee could be
placed on the County Tax Roll. The first installment would likely be received by the CSGSA
in January 2023. It is unlikely that a Proposition 218 fee could be developed and approved
in that short of time. A Proposition 26 mechanism may provide a medium-term funding
strategy. In the immediate term, member contributions may be the most effective option
to fund the GSA.
Corning Subbasin GSP Section 8.9 Short-Term Implementation Start-Up Budget provides
a description of funding needs over the first five years of GSP implementation and
estimates of the expenses. Tables 8-5 and 8-6 offer a reasonable estimate for an initial
budget. Prioritizing immediate term needs to include legal services, fee study, grant
application expenses, fiscal support, annual report, and routine data management system
updates, the budget would be $197,000 for fiscal year 2022/2023. If the estimated
expenses are split evenly among the three members, each member would contribute
$65,667.
If member agencies are agreeable to split the expenses for fiscal year 2022/2023,
recognizing that a medium or long term funding strategy will be in place prior to conclusion
of the fiscal year, an agreement between the agencies would be helpful to create a shared
understanding of the expenses, expectations, and appoint an agency to manage the
funds.
Staff requests direction on the preferred path for funding the CSGSA for fiscal year
2022/2023. This could include direction on:
Short-term funding strategy
Agreement among member agencies
Tasks to include in the strategy and agreement
Fiscal agent
Other options
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Attachments:
Corning Subbasin GSP Section 8.9 Short-Term Implementation Start-Up Budget
Draft Budget Worksheets
Corning Sub-basin GSAPage 107
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Excerpt from Corning Subbasin GSP 2022
C2VSimFG updates should be tracked and incorporated into the NSac model as appropriate.
Future C2VSimFG model updates released by DWR should be evaluated, with major changes
considered for incorporation into the NSac model as part of the 5-year GSP update process.
8.8 Implementation Activity 8: Refine and Implement Projects and
Management Actions
A combination of projects and management actions will need to be implemented to achieve
sustainability in the Subbasin. Section 7 identifies potential projects and management actions
that would help achieve sustainability. The GSAs will refine and assess feasibility and timeline
of the projects and management actions during the first 5 years of GSP implementation. The
projects and actions will be implemented in a coordinated fashion across the Subbasin to achieve
sustainability. Refinement of the projects and actions will occur simultaneously with refinement
of the funding mechanism that supports the projects and actions. Planned activities during the
first 5 years of implementation will include the following tasks as needed:
Performing feasibility studies, as needed, on potential projects
Clarifying water rights and water availability for recharge opportunities
Applying for new or change of diversion, place of use, or timing on new water rights as
necessary
Refining benefit analysis for proposed projects using the groundwater model
Developing proposed project costs
Producing preliminary design of projects if projects are adequately defined
Initiating environmental permitting for projects as necessary
Applying for grant funding
Cost-sharing agreements between the GSAs and other local agencies that may benefit directly
from these projects will be developed as needed.
8.9 Short-Term Implementation Start-Up Budget
Initial GSP implementation budget consists of general administrative costs and additional costs
to cover the 8 implementation activities described above. The following subsections and tables
provide additional detail on estimated initial GSP implementation costs. Costs will be further
refined early in implementation as funding mechanisms are put into place. See Section 8.2 for
additional discussion on anticipated funding sources and mechanisms.
Corning Subbasin Groundwater Sustainability Plan 8-20
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8.9.1 GSA Operational Expenses
The operational expenses of the Corning Sub-basin GSAs will generally include the following
budget category items:
General Management: General management costs include items such as staffing,
administrative support, accounting services, audits, and insurance. It is anticipated that
dedicated staff from Tehama and Glenn Counties will continue to act as the primary
personnel serving the GSAs of the Corning Subbasin. However, staffing needs may also
be contracted out. For planning purposes, it is estimated that at least 2 management-level
staff and 2 administrative-level staff will support the administration of the GSAs on a
part-time basis. Staff serve as the key points of contact for members of the public, the
GSA governing boards, CSAB, and other stakeholders. Moreover, staff are tasked with
fundamental administrative duties, such as hiring and managing consultants, billing and
accounting, development of meeting materials, and organizing outreach efforts.
Technical Services: It is anticipated that the Corning Sub-basin GSAs will have an
ongoing need for on-call consulting and legal services to support regular operations. As
directed by staff, professional consultants may carry out a variety of tasks to support
general analytical needs or provide additional technical capacity on an as-needed basis.
Examples of potential tasks include technical education, legislative and regulatory
interpretation, data analysis (e.g., hydrological, economic, agricultural, etc.), inter-and
intra-basin coordination, opportunities assessments, and program evaluation. Legal
services are currently provided to the GSAs within the Corning Subbasin by the Legal
Counsels of Glenn County, Tehama County, and the member agencies of the CSGSA. It
is expected that these services will continue to be provided to support items such as
contracting, document review, and developing official statements and responses. If
needed, special counsel may be engaged to address other needs (e.g., litigation).
Materials and Outreach: Costs for materials and outreach include items such as website
maintenance, office supplies, materials reproduction, postage, legal noticing, and general
outreach. Funding these items and activities will ensure the Corning Sub-basin GSAs
continue to engage a broad range of stakeholders through a variety of mediums and
comply with all legal noticing requirements. In addition, it will ensure staff will have the
basic supplies necessary to carry out their duties and communicate with relevant entities.
Fees & Assessments: The majority of the GSAs’ GSP development costs have been
funded under a Proposition 1 Planning Grant. In-kind contributions of Glenn County,
Tehama County, and CSGSA member agency staff time have further supported the
coordination needs of consultants, stakeholders, and the CSAB. Implementation of the
GSP will necessitate that the GSAs identify new sources of revenue to fund general
program administration costs and other activities. It is anticipated that the primary source
of new revenues will result from either fees, charges, and/or assessments levied in
Corning Subbasin Groundwater Sustainability Plan 8-21
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November 2021
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compliance with Proposition 26 and/or Proposition 218. A rate study (e.g., Cost of
Services Study, Engineers Report) will be necessary to develop an appropriate funding
methodology, describe the nexus of benefits, establish a recommended charge, and
comply with related legal requirements. There will also be additional procedural costs
(e.g., noticing, ballots, etc.) depending on process and type of charge the GSAs seek to
levy. Public engagement and outreach beyond the minimum legal requirements under the
Proposition 218 and 26 processes will bear additional costs. Once adopted, it is
anticipated that charges will initially be collected by each county on behalf of the GSAs
using their respective tax rolls.
Reserve: GSAs are permitted to fund the costs of maintaining a prudent reserve. Reserve
funds are a common financial management strategy among public agencies that allow
entities to better manage cash flow and mitigate the risk of unanticipated cost overages. It
is recommended that a minimum contingency rate of 10% of all program administration
costs be used when developing the initial reserve fund amount. This rate should be re-
evaluated in the future after the Corning Subbasin GSAs have established several years of
financial activities that can be analyzed to support an updated rate.
Table 8-4 and Table 8-5 provide a summary of the estimated operational costs for each GSA by
budget category and associated line items for the initial implementation phase of the Corning
Subbasin GSP (i.e., 2022 – 2026). Estimated costs are identified as either annual costs or lump
sum costs. Annual costs are directly related to recurring operational work or activities that need
to be funded each year. Lump sum costs are for items that will not recur annually, although their
completion timelines may require more than 1 year. Expenditures for lump sum costs are
anticipated to occur within the 5-year timeframe of the initial implementation phase, but these
costs will not necessarily need to be fully funded in the first year of GSP implementation. Some
costs are anticipated to be borne individually by each GSA, while others may be shared among
the GSAs and other/their member agencies. Because each GSA and/or their members also have
SGMA responsibilities in other subbasins, the actual operating costs associated with their
management of the Corning Subbasin may be further reduced as common staff, materials, and
services are shared across multiple subbasins. Pursuant to the MOU among Corning Sub-basin
GSA members, any future cost-sharing allocations shall be agreed to in writing by the members
in advance of executing any contracts with consultants, vendors, or other contractors or incurring
any expense.
Corning Subbasin Groundwater Sustainability Plan 8-22
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Table 8-4. Estimated TCFCWCD GSA Operational Expenses, 2022 – 2026
\[approximate draft; to be revised during GSP implementation and following additional legal review\]
Annualized Total
Budget Categories and Annual Cost - Lump Sum Items -
5-year Total
Tasks TCFCWCD GSA TCFCWCD GSA
(5 years)
General Management
Management Staff $75,000 $0 $375,000 $75,000
$0
Administrative Support $60,000 $300,000 $60,000
$0
Audits & Accounting $25,000 $125,000 $25,000
$0
Insurance $2,000 $10,000 $2,000
Technical Services
Consulting Services $20,000 $0 $100,000 $20,000
Legal Services$50,000 $0 $250,000 $50,000
Materials & Outreach
Supplies & Materials $5,000 $0 $25,000 $5,000
Legal Notices $1,000 $0 $5,000 $1,000
Community Outreach $12,000 $0 $60,000 $12,000
Fees & Assessments
Fee Studies & Adoption $0 $40,000 $40,000 $8,000
County Tax Roll $10,000 $0 $50,000 $10,000
Grants
Grant Applications $20,000 $0 $100,000 $20,000
Reserve & Contingency
General Reserve (10%) $28,000 $4,000 $144,000 $28,800
Total $308,000 $44,000 $1,584,000 $316,800
Corning Subbasin Groundwater Sustainability Plan 8-23
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Table 8-5. Estimated CSGSA Operational Expenses, 2022 - 2026
\[approximate draft; to be revised during GSP implementation and following additional legal review\]
Annualized Total
Budget Categories and Annual Cost - Lump Sum Items -
5-year Total
Tasks CSGSA CSGSA
(5 years)
General Management
Management Staff $75,000 $0 $375,000 $75,000
$0
Administrative Support $40,000 $200,000 $40,000
Audits & Accounting $15,000 $0 $75,000 $15,000
Insurance $2,000 $0 $10,000 $2,000
Technical Services
Consulting Services $20,000 $0 $100,000 $20,000
$0
Legal Services$50,000 $400,000 $80,000
Materials & Outreach
$0
Supplies & Materials $5,000 $25,000 $5,000
Legal Notices $1,000 $0 $5,000 $1,000
$0
Community Outreach $12,000 $60,000 $12,000
Fees & Assessments
Fee Studies & Adoption $0 $90,000 $90,000 $18,000
County Tax Roll $5,000 $0 $25,000 $5,000
Grants
Grant Applications $20,000 $0 $100,000 $20,000
Reserve & Contingency
General Reserve (10%) $27,500 $9,000 $146,500 $29,300
Total $302,500 $99,000 $1,611,500 $322,300
On an annualized basis, the operational expenses for the TCFCWCD and CSGSA are estimated
to be $316,800 per year and $322,300 per year, respectively, during the first 5 years following
GSP implementation. Total operational expenses on an annualized basis are estimated to be
$639,100 per year during this same period. The costs estimated in Table 8-4 and Table 8-5 will
be refined and their actual allocation re-assessed prior to the implementation of any fees or
assessments by the GSAs. Some estimated costs may be further reduced as a result of the GSAs
and/or their member agencies providing common staff, materials, and services to other basins
within their jurisdiction.
8.9.2 Implementation Activities Funding
Table 8-6 summarizes the conceptual planning-level costs for the initial 5 years of GSP
implementation. These costs do not include costs to implement projects and management actions.
Annual costs are directly related to work that needs to be done consistently to meet the
Corning Subbasin Groundwater Sustainability Plan 8-24
Corning Sub-basin GSAPage 112
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requirements in the GSP Regulations and to fund the 8 implementation activities. This initial cost
estimate will likely change as more data become available and GSP implementation approaches,
and funding mechanisms are developed.
Corning Subbasin Groundwater Sustainability Plan 8-25
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26
-
8
Page 114
; identify well
; review and coordinate
5.
Notes
-
. Recent TSS applications
and landowner
4 and 8
-
responsibilities: administer grant;
Includes costs for GSA administration, communication, outreach, (Section 8.1) and funding mechanisms (Section 8.2) per Tables 8 Placeholder costs for groundwater level monitoringAssumes
$50,000 for first report, $30,000 for subsequent reports Placeholder costs. Expect majority of work to be funded by DWR.Placeholder costsPlaceholder costs Placeholder costs. Expect
work to be funded by DWR TSS grant. GSA coordinate with DWRPlaceholder costs. Expect work to be funded by DWR TSS grant. GSA responsibilities: administer grant; coordinate with DWRlocations;
obtain property accessexecution of agreementsshowed a GSA contribution* of $25,000 for 1 observation well cluster.Placeholder costs. The GSAs will coordinate with DWR to explore the
continuation of regular groundwater quality monitoring in observation well clusters in the SubbasinPlaceholder costs
$2,000 $2,000 $8,000
$50,000 $34,000 $30,000 $20,000 $20,000 $30,000 $25,000
Cost
$639,100
(5 years)
Annualized
year
$10,000 $10,000 $40,000
-
Total
$250,000 $170,000 $150,000 $100,000 $100,000 $150,000 $125,000
5
$3,195,500
$0 $0 $0
$10,000 $40,000
$143,000 $150,000 $100,000 $100,000 $150,000 $125,000
Items
Level Costs for First 5 Years of Implementation
-
Lump Sum
$0 $0 $0 $0 $0 $0 $0
$2,000
$50,000 $34,000
Cost
$610,500
Annual
Estimated Planning
.
6
-
8
Table
Monitoring
conceptual model
Groundwater Sustainability Plan
year Update
Budget Categories and Tasks
-
GSA Administration, Program Management, and Funding Monitoring & Reporting Groundwater Conditions Annual Reports ($50,000 for first report, $30,000 for subsequent reports) GSP 5 Address
HCM and Groundwater Conditions Data Gaps AEM or other geophysical testing to refine hydrogeologic Aquifer testing to refine hydrogeologic conceptual modelGDE mapping Expand Existing
Monitoring Networks Videologging of wells with unknown screen intervalsInstall 5 new observation wellsCoordinate with DWR to continue groundwater quality monitoringAssess modification
or replacement of surface water gages on Thomes Creek
Subbasin
ember 2021
346
1 and 2
Activity
Corning Corning Sub-basin GSA Nov 5/11/22 Meeting Materials
27
-
8
Page 115
Notes
)
Placeholder costs.Placeholder costs for updating Tehama Co well database similar to Glenn Co update, in collaboration with the other Tehama County GSPs and updating the Glenn County
database.Placeholder costs for developing a pilot well registration program.Placeholder costsDepends on projects and management actions pursued; Could be grant or project match; Will
be coordinated with agencies that benefit.
$10,000 $10,000 $10,000 $30,000 $60,000 $95,310
Cost
(5 years)
$1,078,110
Annualized
$50,000 $50,000 $50,000
year
$150,000 $300,000 $490,050
-
Total
5
$5,390,550
$0 $0
$50,000 $50,000
$150,000 $106,800
$1,174,800
Lump Sum Items
$0 $0 $0
$10,000 $60,000 $76,650
Cost
$843,150
Annual
registration pilot program and well database updates.
kind staff time to collect and manage data and maintain equipment over the useful life of the well (approximately 20 years
-
Refine Groundwater Model
Groundwater Sustainability Plan
Data Management System
Budget Categories and Tasks
Update Routine Data Management System UpdatesWell Database UpdateWell Registration Pilot Program Update and Contingency (10%)TOTAL
Evaluate, Prioritize, and Refine Projects and Management Actions
Subbasin
ember 2021
678
Activity Notes: Some of the line items may be optional costs, such as well Some of the implementation activities may be delayed beyond the first few years to allow for funding to be
arranged.*GSA contribution is expected to encompass in Corning Corning Sub-basin GSA Nov 5/11/22 Meeting Materials
Page 116
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Initial Budget Worksheets FY 2022/2023
Page 117
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Page 118
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12. Discussion on Funding Mechanisms for GSP Implementation
a. *Appoint an ad hoc committee to develop and release a Request for Proposals to
solicit a consultant to develop and implement one or more funding mechanisms
for Corning Subbasin GSP implementation
At the January 12, 2022 CSGSA meeting, members indicated a desire to begin having
more detailed discussions regarding funding mechanisms and a potential path forward to
fund GSP implementation. Staff kicked off these discussions at the February 9, 2022
meeting by sharing past presentations by the Consulting Team to the Corning Subbasin
Advisory Board, letters provided by interested stakeholders, and other relevant
information. Discussion continued at the March 9, 2022 and April 13, 2022 meetings. At
the April 13, 2022 meeting, the discussion was broken into two parts- one to focus on
short-term funding needs (discussed during Item 11) and one to focus on long-term
implementation and funding mechanisms.
Significant discussions have taken place relating to potential and preferred options,
concerns and benefits of options, data needs, timing, level of effort, and other related
items. In order to effectively move the longer term discussion forward, staff recommends
beginning the process of hiring a consultant to guide the funding mechanism process,
which may include short/medium term funding, long-term funding, and/or project specific
funding. Moving the process forward could include appointing an ad hoc committee of two
members to work with staff to develop and release a Request for Proposals. If desired, the
committee could also manage the solicitation, review proposals, interview applicants, and
bring a recommendation to the CSGSA for approval. The process to bring a
recommendation to the CSGSA is expected to take approximately 10-12 weeks.
This process will also require legal counsel input; therefore, the discussions during Item 7
and Item 11 are relevant to this task as well.
13. Corning Sub-basin GSA Committee Member Reports and Comments
Members of the CSGSA Committee are encouraged to share information, reports,
comments, and suggest future agenda items. Action cannot be taken on matters brought
up under this item.
14. Next Meeting
The next meeting is scheduled for June 8, 2022 at 9:30 a.m.
15. Adjourn
The meeting will be adjourned.
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County of Glenn
Glenn-Colusa Irrigation District
Monroeville Water District
Corning Sub-basin GSA Committee
Meeting Minutes
May 11, 2022 | 9:30 am
Glenn-Colusa Irrigation District Pump Station
7854 County Rd 203, Orland, CA 95963
Public participation was also offered via teleconference
1. Call to Order
John Amaro called the meeting to order at 9:35 a.m.
2. Roll Call
Party Representative Member Agency
X Tom Arnold County of Glenn
X Grant Carmon County of Glenn
X John Amaro Glenn-Colusa Irrigation District
X Pete Knight Glenn-Colusa Irrigation District
Julia Violich Monroeville Water District
Seth Fiack Monroeville Water District
Lisa Hunter conducted roll call as noted above.
3. Meeting Minutes
a. *Approval of April 13, 2022 meeting minutes
No corrections or comments were made on the draft minutes.
On a motion by Mr. Arnold, seconded by Mr. Knight, the meeting minutes of April 13,
2022 were unanimously approved as presented.
4. Period of Public Comment
Matthew Sturdivant introduced himself as a consultant with LSCE and was
listening in on behalf of Eddy Teasdale.
5. Staff Reports
Ms. Hunter shared the Airborne Electromagnetic Survey (AEM) that Department of
Water Resources (DWR) is conducting statewide is expected to be in this area
from approximately April 26 through May 23. More information can be found
225 North Tehama Street Willows, CA 95988 530.934.6540
online at: https://water.ca.gov/Programs/Groundwater-Management/Data-and-
Tools/AEM
Mr. Knight asked how accurate the information is; whereby Ms. Hunter explained
the general method and the need for known data (detailed well log data) to
correlate with AEM data. Pat Vellines, DWR, shared there will be a public meeting
relating to this topic, but the date has not yet been set. Ritta Martin asked if the
area to the west of Black Butte Lake would be covered under this survey. Ms.
Hunter encouraged her to review the DWR website which will show the flight lines
after the survey is conducted. Ben King stated the Groundwater Resources
Association (GRA) will be holding a webinar on this topic. Ms. Hunter also noted
that portions of the Colusa and Corning Subbasins were included in the Butte
County pilot study about three years ago and that information is also available.
Ms. Hunter reviewed the status of the Proposition 1 grant the associated
agreement with Montgomery & Associates (M&A). She noted the second
amendment for the grant had been approved which extended the administrative
task through June 30, 2022. The M&A contract has expired and there is no
longer consultant support.
Ms. Hunter reported the future Sustainable Groundwater Management Grants are
expected to open a Round 2 solicitation in September 2022 with agreements
being executed in July or August of 2023.
6. Presentation: Land IQ
Joel Kimmelshue, Land IQ, gave a presentation that provided an overview of Land
IQ, its history, and applications of the work product. He reviewed examples of
monthly field by field evapotranspiration, precipitation, and land use data that
has been used for SGMA compliance. He also showed examples of how this tool
can be used in the urban setting and cropping trends.
Del Reimers asked if soil type is accounted for; whereby Mr. Kimmelshue
answered that information is available.
Pete Knight asked for clarification on applied versus consumed water. Mr.
Kimmelshue responded the demand is the demand; however, an individual can
pump less, for instance, applying deficit irrigation during certain periods.
Individual economics then considers the degree that action impacts the crop and
to what degree versus water savings.
Ian Turnbull asked about the error associated with the data and how GSAs that
are billing based on this data are dealing with variability. Mr. Kimmelshue
responded the accuracy is estimated at +/- 5-7% based on measurements in
field.
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Mr. Turnbull asked for clarification on the land use error. Mr. Kimmelshue stated
the error is tied to crop type. Rice is over 99% correct and almonds are 98.8%
accurate. Fallow versus first year tree crops are less accurate and ground-truthing
helps to increase the accuracy with that. Mr. Turnbull provided an example of a
GSA that is using a charging structure based on well inventory rather than
irrigating/not irrigating. Mr. Kimmelshue noted GSAs can use remote sensing ET
data or meter on a well to determine water use and the pros and cons must be
weighed to choose the right tool for the GSA. Discussion ensued.
Ms. Hunter asked if GSAs have used this method for billing based on ET in areas
with mixed groundwater/surface water use and how that could be reconciled. Mr.
Kimmelshue replied Land IQ cannot tell the water source. On the ground stations
have rain gauges, so precipitation can be measured and reconciled with the ET
values.
Del Reimers asked if the Land IQ data knows where all the irrigated acres are. Mr.
Kimmelshue stated then land use is mapped out with 97.6% accuracy and the
Land IQ data goes back to 2014. Mr. Reimers asked about the cost the data;
whereby, Mr. Kimmelshue said they charge by the acre for ET work and
depending on complexity, it could range from about $0.65- $2.00 per acre.
Mr. Turnbull asked how quickly a change in crop type is detected. Mr.
Kimmelshue responded the detection is correlated to size of project. Small areas
can be assessed in about a month. Some data is seasonal and would also need
to be accounted for.
Mr. Carmon asked about a cost estimate for irrigated versus non-irrigated lands.
Mr. Kimmelshue stated that type of project would be on a time and materials
basis.
Mr. Reimers asked if the DWR data is public; whereby Mr. Kimmelshue answered
that it is and offered free of charge to the public. He further noted that some
areas need the information faster or need additional information, and therefore,
pay to have the work done independent of the DWR dataset. Peak date tracking
can also provide useful information. Discussion ensued on timing and
applications of the data.
Ben King suggested this work be done at the IRWM level and noted this could be
a good way to distinguish between rangeland and irrigated acreage and may be a
more economical effort than metering. Mr. Kimmelshue suggested speaking with
other GSAs that have similar situation as far as land use.
The committee thanked Mr. Kimmelshue for presenting.
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7. Discussion on Legal Counsel to represent the CSGSA as needed
Ms. Hunter summarized the committee began discussing this topic in March. It
was reported in April that Glenn County, County Counsel suggested the CSGSA
seek the services of an experienced water attorney and the committee requested
Ms. Hunter reach out to Valerie Kincaid of Paris Kincaid Wasiewski, LLP to
determine if the firm would be interested in serving as counsel to the CSGSA. Ms.
Kincaid responded affirmatively. Staff requested direction from the committee.
Holly Dawley asked if the CSGSA has a procurement policy. Members shared
respective relevant policy information. A simple on-call services agreement was
discussed.
Mr. Knight asked if there is anything coming that needs immediate attention. Ms.
Hunter replied the upcoming funding and budget discussions would likely need
counsel advice and also any potential agreements among the members.
Mr. King stated he is opposed to hiring a water attorney for day-to-day business
and county counsel could be used for Brown Act compliance. A specialized
attorney could be useful for targeted advice like fee studies.
Ms. Dawley suggested getting a list of qualifications from Ms. Kincaid and bring
that to the next meeting. Having someone on-call does not preclude the
committee from adding others for specific purposes. Discussion ensued. Mr.
Carmon suggested reaching out to Michael Colantuono relating to the fee
discussions.
Governance and fees currently imposed in the region were summarized and
discussed.
Staff was directed to request a draft contract and list of qualifications from Ms.
Kincaid and to reach out to Mr. Colantuono. This topic will come to the next
meeting as a possible action item.
8. Corning Subbasin Groundwater Sustainability Plan
a. Discussion on Corning Subbasin Groundwater Sustainability Plan implementation
and next steps
Ms. Hunter stated the links to the Groundwater Sustainability Plan (GSP) and
Annual Reports are located in the meeting packet and comments received on the
GSP are included in the meeting packet.
Ms. Hunter indicated the total cost of the Annual Report beyond what the grant
covered is approximately $12,000; however, not all the invoices are in yet.
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Mr. King asked how the cost of the Corning Annual Report compared to the
Colusa Subbasin Annual Report; whereby Ms. Hunter indicated the costs were
comparable.
9. Corning Subbasin Advisory Board Report
Mr. Amaro stated there was robust discussion on the Annual Report presentation
at the April 6, 2022 CSAB meeting, which was covered in the report at the April
13 CSGSA meeting.
Ms. Hunter announced the next CSAB meeting is scheduled for June 8, 2022.
10. Discussion on Executive Order N-7-22
a. *Approve Well Permit Acknowledgement Form and authorize staff to finalize
process with the Glenn County Environmental Health Department
Mr. Amaro introduced the item and referenced the materials included in the
meeting packet.
Ms. Hunter summarized the background materials and discussion from the April
13, 2022 CSGSA meeting and noted that several GSAs in the region are using a
very similar Well Permit Acknowledgement Form.
Mr. Carmon stated that because replacement ag wells are being allowed under the
current well permit moratorium, it is important to have the Acknowledgement Form
in place to comply with the Executive Order. Mr. Amaro agreed.
Mr. King asked a question relating to replacement well depth. Mr. Carmon
responded that per the moratorium the replacement of a failed ag well is allowed
to go deeper than the original, but no bigger in diameter than the original well. Mr.
King relayed concerns about water quality at depth and suggested well depths be
recorded; whereby Mr. Carmon noted well depth is recorded on the logs.
On a motion by Mr. Carmon, seconded by Mr. Knight, it was unanimously approved to
send the proposed draft to the County and receive their input.
11. Corning Sub-basin GSA 2022/2023 Budget
a. Discuss Short Term Funding Strategy
b. Provide direction on a proposed agreement among member agencies to fund
specific tasks or explore other potential options to meet short term funding needs
Ms. Hunter stated the funding item has been discussed at the last few CSGSA
meetings and the committee requested that some additional information and
figures be brought back for consideration. Ms. Hunter reviewed the draft budget
provided in the GSP. If immediate term items are prioritized, the budget would be
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hare would
be $65,667.
Mr. Amaro noted that although Glenn County has provided administrative services,
GCID does not have a large footprint in the basin and perhaps another allocation
method could be used. Mr. Knight asked if reimbursement at a later date would be
possible.
Mr. King asked if the GCID deep wells are located in the subbasin and noted that
even if their footprint is small, they may still pump groundwater.
Mr. Amaro suggested this be brought to the member boards for discussion. Mr.
Carmon suggested moving forward with an immediate interim funding mechanism
to help with these initial costs. Discussion ensued on initial budget figures,
considerations, and processes including local examples.
Mr. Carmon suggested to request each member provide a contribution of $40,000.
Members agreed to take the request to their respective member agency.
Mr. Reimers shared concerns about equitable distribution of charges, particularly
related to the rangeland areas. Pete Knight exited the meeting at approximately
11:25 a.m. Discussion ensued and there was general agreement in structuring a
fee that accounts for different land uses.
12. Discussion on Funding Mechanisms for GSP Implementation
a. *Appoint an ad hoc committee to develop and release a Request for Proposals to
solicit a consultant to develop and implement one or more funding mechanisms
for Corning Subbasin GSP implementation
The CSGSA was not in favor of creating an ad hoc committee. Ms. Hunter stated
the reason for the proposed ad hoc committee would be to serve as a working
group to prepare a draft Request for Proposals (RFP) and bring to the next board
meeting in a final draft form.
At
serve on an ad hoc committee to bring a draft RFP to the CSGSA for
consideration.
Mr. Reimers asked for clarification on the $0.29 charge in Tehama County and
how much of that funding will support the Corning Subbasin. Discussion ensued
on and GSP implementation
for their portion of the subbasin through their own funding mechanism (GSA
specific). There will also be shared costs and the GSAs will need to decide how to
split those costs. It is expected shared costs will be a future CSAB meeting topic.
Mr. Turnbull commented that early in the SGMA process, a proposal was made to
split the Corning Subbasin at the County line, and there was little support for that
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proposal, which ultimately did not pass and the subbasin basin remained a single
subbasin.
Ms. Martin asked if a representative from the non-irrigated lands areas could be
added to the ad hoc committee. There was some discussion on the amount on
non-irrigated acreage within the CSGSA. Ms. Lely
Ms. Hunter clarified the ad hoc committee would only be developing the RFP and
bringing it back to a future meeting, not managing the RFP or the funding
King suggested public participation at the ad hoc committee be allowed. The
committee was left as is, but there was a commitment to bring more detailed
funding mechanism discussions to board meetings during the process.
13. Corning Sub-basin GSA Committee Member Reports and Comments
Mr. Carmon announced the Drought Task Force meeting is scheduled
for May 12 at 3:00 p.m. DWR and GCID will each provide a report as well as an
update from DWR and the City of Orland on project.
14. Next Meeting
The next CSGSA is scheduled for June 8, 2022 at 9:30 a.m.
15. Adjourn
The meeting was adjourned at 11:48 a.m.
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