Comments on 180/400 GSP Update
John Farrow
Dear Members of the Board,
Attached are LandWatch's comments on the 180/400-Foot Aquifer Subbasin GSP Update.
LandWatch’s comments point to areas in which GSP Update creates roadblocks to management of the subbasin through actions to control extractions.
- First, the decision to
abandon the existing extraction-based Minimum Threshold (MT)
for storage loss and to adopt an MT based on groundwater
levels will frustrate adoption of management actions intended
to control extractions because, as staff admit, it is "almost impossible to show a significant
correlation between groundwater elevations and 'a total volume
that can be extracted.'"
- Second, setting sustainable management criteria based on groundwater levels below sea level prematurely abandons the strategy of restoring and maintaining protective groundwater elevations to control seawater intrusion. This leaves the GSA reliant on the proposed pumping barrier as the sole means to control seawater intrusion, even though this project has not been demonstrated to be feasible either technically or economically.
LandWatch’s comments also point out that the SVIHM and SVOM modeling in Chapter 6 is not calibrated with empirical data and presents a water balance that does not in fact balance. The modeling results are misleading and should be relegated to an appendix. The GSP should simply admit that reliable modeling does not yet exist.
Finally, LandWatch objects again that the GSP Update fails to state overdraft conditions clearly by presenting a single measure of overdraft that includes overdraft represented by falling groundwater levels and overdraft represented by seawater intrusion. Instead, the GSP Update repeatedly mischaracterizes overdraft as consisting of only the 800 AFY attributable to falling groundwater levels, ignoring the additional 12,600 AFY overdraft component represented by seawater intrusion. The total overdraft figure, 13,400 AFY, must be clearly stated because the GSP must identify “projects and management actions, including a quantification of demand reductions or other methods, for the mitigation of overdraft.” (23 CCR, § 354.44(b)(5).)
Although many of these comments were made to the 180/400 Subcommittee as staff released chapters for comment, the GSP Update does not adequately address these comments. Since a GSP must demonstrate that the GSA “has adequately responded to comments that raise credible technical or policy issues with the Plan,” LandWatch asks that the current GSP draft be revised to address these comments. (23 CCR, § 355.4(b)(10).)
Thank you for your attention,
John H. Farrow
M. R. Wolfe &
Associates, P.C. | Attorneys
Land Use | Environmental Law | Elections
415.369.9400 | Fax: 415.369.9405 | www.mrwolfeassociates..com