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HomeMy WebLinkAbout12/7/2021 Item 6a, Blakely Delgado, Adriana From:4385956@gmail.com Sent: 1, 2021 11:01 AM To:E-mail Council Website Cc:Floyd, Aaron Subject:December 7th Agenda - Comments on Ground Water Sustainability Plan- David Blakely Attachments:SLO Groundwater Plan 2021.pdf This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Please include my letter as comments on the SLO Valley Basin Groundwater Sustainability Plan All the best, David Blakely 1 D AVID B LAKELY 861 S KYLINE D RIVE S AN L UIS O BISPO, CA 93405 September 5, 2021 Dear San Luis Obispo City Council, Re: Public Draft of the Groundwater Sustainability Plan Thank you for the opportunity to provide comments on the Public Draft of the Groundwater Sustainability Plan. I appreciate all of the good work being done to understand and plan for the sustainability of the SLO Basin. In general, my major concern with this plan is that it relies too much on unrealistic supply side solutions to the problem of overdraft of the Edna Sub Basin instead of focusing on demand management practices and changes in land use planning and other public policy initiatives that can improve that basin. This draft plan relies too much on the uncertain acquisition of State Water Project (SWP) water to back bill the overdraft of the sub basin. Given the past history and current reliability problems with the SWP this is a low to no probability solution. It is improper to suggest it as a solution when there is little to no chance it can or will be implemented. Focusing on getting access to the SWP will just delay any real solution to this sustainability issue in the Edna sub basin. While this plan does mention demand management solutions, they are all voluntary and have a low probability of implementation. Once again, these voluntary fixes are not real fixes at all and will delay any real solution to the sustainability problem of the Edna sub basin. An unrealistic reliance on the SWP and voluntary conservation measures can potentially jeopardize the entire plan and cause its approval by the State to be delayed and exacerbating the overdraft problem requiring even more draconian solutions. Below are some specific comments on the Draft Plan. All the best, David Blakely David Blakely Comments: Page ES-16 In the Section entitled: The seven projects evaluated as part of the GSP It does not seem reasonable, to even consider using potable water from the State Water Project for agricultural uses. Given the need for potable water in the state it seems absurd to even consider this as an option. To even consider this as an option provides an inaccurate tilt to the conclusions of this study. I believe that any agricultural use of SWP be stricken from this document. Page 5-ant drop in the ground water levels in the Edna valley. The cause of this drop must be understood. If the drop is because of ground water pumping to irrigate the agricultural uses it must be contemplated to limit this pumping which may cause problems for residential uses in this area. The major problem is in the southern areas (Edna Valley) of the basin. County planning should address this precipitous water level drop and the city of SLO should understand its impact on the down gradient ground water levels. The map on page 5-14 illustrates this problem. This is not sustainable. Page 5-15 This map illustrates the effects of the resent drought and agricultural ground water pumping in this area. Continued or increased agricultural use in this area will be detrimental to all users in the basin. Page 5-35 Section 5.9.1 In the discussion of ground water suitability for drinking water there appears to be a nitrate problem. Can any of that increase in nitrates be attributed to agricultural uses overlying the basin? If there is a correlation, there should be a program to reduce this impact. Map on 5-3 Shows the areas of Nitrate concentration. These areas should have a plan to mitigate this impact as part of this document. Page 6-2 Table 6-11 This table appears to show that pasture uses are the most water intensive and vineyards tend to be much lower. If that is the case, then there should be a program to phase out pasture uses and transfer that water to other less demanding uses. Maybe a program like the one used in the Paso Basin for the open sale of water rights should be considered. Page 6-63 From the plan 6.6.1.1. Future Water Demand Assumptions For the purpose of evaluating the effects of climate change and future baseline water budget development, the assumption is made that there will be no increase in irrigated acreage or agricultural pumping over the SGMA planning horizon. There is no evidence in the record to indicate that this statement is true. It is appearing to be based on the statements of the users that are contributing to the overdraft. Evidence of the stabilization of this overdraft must be part of the record. There is no evidence in the record that indicates that there will be no increase in the amount of pastureland in the Edna Valley and there is no evidence that there will be a halt to any increases in water usage in this area. Page 8-5 8.3.2. Sustainability Strategy The sustainability strategy was developed and discussed at numerous public meetings of the GSC. Projects and management actions were developed collaboratively with GSA Staff, GSC members, and the public utilizing the guiding principles of the Sustainability Goal. A total of seven (7) projects are evaluated in Chapter 9 (Projects and Management Actions) and are centered around supplemental water sources that could be brought into the SLO Basin to mitigate the overdraft. In addition to the projects, three (3) management actions will be implemented. The implementation of a combination of projects and the management actions listed below will ensure that the SLO Basin will operate within the sustainable yield and achieve sustainability as described in the following sections of this Chapter. er Project Recharge Mutual Water Company Arroyo Plan It is ludicrous to assume that the SWP will help in any way to solve this problem. The agricultural stakeholders appear to think that there is a solution by using SWP water to help replenish their over drafted water supply. There is a very low probability that the SWP can provide a solution to this problem. There must be an explanation of how it makes sense to use potable water for agricultural uses and there also must be an explanation of the reliability of the SWP in suppling water to be used to solve this overdraft issue. The focus should be on figuring out a way to better utilize the limited resource that has been determined by this report as the sustainable yield in that sub region. The solution is not in increasing supply but by demand management. The County of SLO must develop policies that do not further degrade the sustainability of the Edna Valley sub basin. Page 8-24 the MT for reduction in groundwater storage may limit or reduce non-de minimis production in the Basin by reducing the amount of available water. The practical effect of these MTs on agricultural users is that current levels of agricultural pumping may not be sustainable without development of additional sources of water to the Basin. Owners of undeveloped agricultural lands that are currently not irrigated may be particularly impacted because the additional groundwater pumping needed to irrigate these lands could increase the Basin pumping beyond the sustainable yield, violating the MT. Existing agricultural operations may also be limited in their use of more water-intensive crops, expansion of existing irrigated lands, and by periods of extended drought that decrease the quantity of water naturally returning Once again, this report indicates that the solution to the over drafting of the Edna Valley is to develop work on the demand portion of the overdraft problem. There are many strategies for doing this. Many strategies will have little impact on the current users and increase sustainability in the basin. Page 6-9 Chart The city of SLO should not be transferring any of its water to Ag users who are over pumping their aquifers. The city needs all the water they can get. I have not heard the city indicate that they have surplus water to sell to anyone. If the city has excess reclaimed water, they should be developing a delivery system to use it appropriately within the city. On this chart two projects are listed to deliver water via the SWP to GSWC and Mutual Water Companies for a total of 100 AFY of water. Before such a plan should be considered water reliability from the SWP must be considered. The sunk cost of any new water deliveries from the SWP must be considered as they may be so high that the price of this water is not acceptable. Just because you can list the SWP as a solution to the problem with sustainability in this area does not mean that it a solution to that issue. The problem is compounded if this new water is growth inducing leading to no net gain in fixing the sustainability issue. If the new water is growth inducing an Eir will be required leading to more cost and future delays. To include the SWP as any mitigation to this problem is a distraction and provide at best a false hope that the problem of sustainability can be corrected with SWP. Page 9-11 Table 9-5 Once again the plan dishonestly presents the SWP as a potential solution to the issues of overdraft. Page 9-12 ly and may require dichlorination before being used for This statement from this document illustrates one of the problems with using SWP water. This problem is identified but there is no discussion on how dichlorination works and what the environmental impacts might be. subcontractors that receive their SWP water through Lopez and Chorro Valley Participants, 2) Santa Barbara County Participants or 3) a portion of the SLOCFCWCD's unsubscribed Table A amount (14,463 AFY). Any necessary agreements/terms would need to be identified, negotiated, and developed amongst relevant parties, and environmental review would need to be conducted, to facilitate the transfers. The recent adoption of the Water Management Tools Amendment to the SWP Contracts by the SLOCFCWCD and the Santa Barbara County Flood Control and Water Conservation District (SBCWCFCD) presents new opportunities for obtaining SWP water This section illustrates the insurmountable problems with the notion that the SWP can ever be possible as a solution to the overdraft issue. This is another reason why it is silly to include it as a potential solution. The model was run continuously for the time period from water years 1987 through 2044. This project simulation assumes that 1,000 AFY of SWP water is available for agriculture to offset irrigation supply currently supplied by This statement is misleading at best. There has never been a year in which the SWP has been able to deliver the full entitlements of the system. The planning done for this scenario should at least be based on honest delivery amounts. Another assumption that cannot be made is that the SWP water will be available in 2026. Given the strong desire for urban use of the SWP water I do not believe that there will ever be a decision to allow that water to be used for ag purposes. Page 9-15 9.4.1.2. Supply Reliability (§ 354.44.6) The latest estimates of anticipated SWP availability under future conditions are included in the Department of Water Resources 2019 SWP Delivery Capability Report (DCR) (DWR, 2019). The 2019 DCR anticipates approximately 58% of the This is evidence that the SWP indicates a small amount of water can actually be delivered. Therefore, to get 1000 AF of state water a much larger amount will need to be purchased. Even in wet years the SWP is not able to deliver its contracted amounts. This report identifies this reliability problem but goes on as if the full entitlement can be delivered. Its analysis assumes full delivery and though it states this delivery issue it does not include it in documentation to justify its use. To use the SWP as a mitigation to the overdraft problem will make it appear that the basin is working toward a solution. In reality this non solution and its pursuit will make worse the overdraft problem because no real action will be taken. 9.4.1.4. Project Implementation (§ 354.44.4) Investigating the use of SWP as a supplemental water source would occur within the first year of implementation. Following the recommendations of the feasibility study, negotiations to acquire SWP from the identified sellers could take up to 5 years. The design and construction of the turnout and pipeline could occur This is an unrealistic and dishonest timeline. Nothing dealing with the SWP can happen in 5 years. There is no evidence in this record that indicates this project can happen in five years. Simply stating that it can happen in 5 years and realistically even getting to a decision on this solution could take much longer if at all. Page 9-16 This section provides information that indicate that the transfer of water from the city to the over drafted basin is not a viable solution either. At the beginning of this process the city may be able to provide some water, but the city has indicated that it will probably be reducing this water to the basin users. May reasons are given as to why the city will reduce the quantity of available water to outside users. Therefore, this should be eliminated from the list of potential solutions to the overdraft issue. Page 9-37 9.5.3.2. Irrigation Efficiency Improvements The information in this section may be correct but it not proper to use this data in connection to demand management in the Edna valley. This model assumes that crop uses will remain constant and then through efficiency this constant use will be reduced. The flaw in this scenario is that it does not control for change in use to a more water intensive use. The report also states that even the information in this model is conceptual. Without more concrete factual information to suggest that irrigation efficiency will help to improve the overdraft in the basin this solution is purely speculative. Page 9-38 9.5.3.3. Volunteer Water Efficient Crop Conversion Any mitigation that relies on voluntary participation is by its nature unreliable and should not be considered as a mitigation for overdraft. The same is true for Volunteer Land Fallowing. Unless these solutions are required there is a very low probability of their implementation. Page 10-2 10.1.3. Implementation Costs Implementation Cost should be borne by the entities causing the lack of sustainability not by the general public. The general public did not cause this problem. It should be fixed by those users contributing to the overdraft. Page 10-3 In this timeline the scheduling for the Project Implementation is extremely optimistic. The report should do a be again, the cost to develop the Supplemental Water Feasibility Study should be funded by the property owners who will benefit by its implementation. The people causing the overdraft and lack of sustainability of the sub basin should shoulder the cost of the project that will fix the problem they have created. We are privatizing the benefits and socializing the cost. Section 10.2 makes it appear that costs are anticipated to be covered by project proponents yet there is no discussion of methods to be used to make this happen.