Santa Margarita Groundwater Agency · 24.09.2020 · pursuant to title ii of the americans with disabilities act of 1990, the santa margarita groundwater agency requests that any

Principal Office: 2 Civic Center Drive, Scotts Valley, CA 95066 Website: www.smgwa.org

Santa Margarita Groundwater Agency Board of Directors Meeting Agenda

Date: September 24, 2020 Time: 5:30 p.m. Location: Remote Only

This meeting will be held in a remote-access format that complies with Executive Order N-29-20 issued by the California Governor’s Office.

The meeting may be accessed from a computer, tablet or smartphone. https://global.gotomeeting.com/join/289587893 Phone call-in is available by dialing: +1 (646) 749-3122

Access Code: 289-587-893

Remote access will be open 15 minutes before the start of the meeting.

1. CONVENE MEETING

1.1 Call to Order and Roll Call

1.2 Additions/Deletions to the Agenda

1.3 Oral Communications on Matters Not on the Agenda

2. ADMINISTRATIVE

2.1 Approval of Minutes – August 26, 2020 Special Board Meeting

2.2 Approval of Minutes – August 27, 2020 Regular Board Meeting

3. CONSENT

None

4. GENERAL

4.1 Status of Projects and Management Action Development for the GSP

4.2 Informational Session – Groundwater Sustainability Plan (GSP) Elements

4.2.1 GSP Roadmap – September 24, 2020

4.2.2 Sustainable Management Criteria for Depletion of Interconnected Surface Water, Degraded Groundwater Quality, Chronic Lowering of Groundwater Levels, and Reduction of Groundwater Storage (Dave Ceppos [California State University, Sacramento], Georgina King [Montgomery & Associates], and Chelsea Neill [Balance Hydrologics])

Presentation slides and supplemental materials for these items will be made available at www.smgwa.org.

a. Undesirable Results for Degraded Water Quality, revisit Minimum Threshold for Nitrate (40 minutes)

https://global.gotomeeting.com/join/289587893

http://www.smgwa.org/

b. Minimum Thresholds and Undesirable Results for Chronic Lowering of Groundwater Levels (30 minutes)

c. Significant and Unreasonable Conditions, Minimum Thresholds and Undesirable Results for Depletion of Interconnected Surface Water (40 minutes)

d. Introduction to Reduction of Groundwater in Storage Sustainability Indicator, and Proposed Approaches for Minimum Thresholds and Measurable Objectives (30 minutes)

Recommendation: Receive information and provide input; approve draft minimum thresholds for groundwater quality relating to nitrates.

5. STAFF REPORTS

Staff Reports will be presented quarterly

6. DIRECTORS REPORTS

Directors Reports will be presented quarterly

7. FUTURE ITEMS

- Records Retention Policy

- Financial Controls for Borrowing Money

Informational Sessions

- Groundwater Sustainability Plan Elements

8. INFORMATIONAL ITEMS

None

9. EVENTS CALENDAR

- 2020 ACWA Summer Conference and Exhibition, December 01 – December 04, 2020 Virtual Event

10. ADJOURNMENT

The next scheduled Board of Directors meeting will be at 5:30 p.m. on October 22, 2020.

PURSUANT TO TITLE II OF THE AMERICANS WITH DISABILITIES ACT OF 1990, THE SANTA MARGARITA GROUNDWATER AGENCY REQUESTS THAT ANY PERSON IN NEED OF ANY TYPE OF SPECIAL EQUIPMENT, ASSISTANCE OR ACCOMMODATION(S) IN ORDER TO

EFFECTIVELY COMMUNICATE AT THE AGENCY’S PUBLIC MEETING PLEASE MAKE SUCH A REQUEST TO THE SANTA MARGARITA GROUNDWATER AGENCY AT 2 CIVIC CENTER DRIVE, SCOTTS VALLEY, CA 95066, OR BY CALLING (831) 438-2363 A MINIMUM OF

THREE (3) WORKING DAYS PRIOR TO THE SCHEDULED MEETING. ADVANCE NOTIFICATION WITHIN THIS GUIDELINE WILL ENABLE THE DISTRICT TO MAKE REASONABLE ARRANGEMENTS TO ENSURE ACCESSIBILITY.


Santa Margarita Groundwater Agency Board of Directors Special Meeting Minutes Date: August 26, 2020 Time: 5:30 p.m. Location: Remote Access Only

The County of Santa Cruz and the State Governor had issued shelter-in-place orders that were in effect during

the time of this meeting. In accordance with these orders, the Santa Margarita Groundwater Agency conducted its August Board of Directors meeting in an exclusively remote-access format.

1. CONVENE MEETING

1.1 Call to Order and Roll Call Chair Perri called the meeting to order at 5:33 p.m.

Directors (Alternates acting as voting Directors shown in italics): E. Cassidy, J. Dilles, D. Engfer, A. Franklin, R. Moran, D. Pollock, R. Stiles, L. Henry, C. Perri Alternates (Present as non-voting observers): B. Ekwall, J. Koopman, D. Lind Staff: C. Blanchard, P. Harmon, R. Menard, J. Ricker, S. Ryan, N. Wallace Others: S. Chartrand, G. King, T. Rein, C. Tana


None.

1.3 Oral communications on items not on the Agenda

Two comments were heard from individual Directors.

2. ADMINISTRATIVE BUSINESS

2.1 Approval of Minutes – July 23, 2020 Board Meeting MOTION: Dilles/Pollock to approve the July 23, 2020 Board of Directors meeting minutes. AYES: E. Cassidy, J. Dilles, D. Engfer, A. Franklin, R. Moran, D. Pollock, R. Stiles, L. Henry, C. Perri NOES: None ABSTAIN: None ABSENT: J. Leopold, B. McPherson

2.2 Term Expiration of Well Owner Representatives for term ending August 27, 2023

2.1-1

MOTION: Henry/Stiles to re-appoint Edan Cassidy and Angela Franklin as Well Owner Representatives

for the term ending August 27, 2023. AYES: E. Cassidy, J. Dilles, D. Engfer, A. Franklin, R. Moran, D. Pollock, R. Stiles, L. Henry, C. Perri NOES: None ABSTAIN: None ABSENT: J. Leopold, B. McPherson

3. GENERAL BUSINESS

3.1 Information Session – Climate Change Scenarios and Groundwater Modeling (Dave Ceppos [California State University, Sacramento], Shawn Chartrand [Balance Hydrologics], and Cameron Tana [Montgomery & Associates])

- Climate Change Scenario to be Used in Predictive Groundwater Modeling

- Groundwater Modeling Update

S. Chartrand presented information to the Board on climate change scenarios considered for use in the SMGWA Groundwater Sustainability Plan and responded to questions.

C. Tana presented information to the Board on the status of groundwater modeling improvements and responded to questions.

Two public comments were heard.

4. ADJOURNMENT

MOTION: Cassidy/Stiles to adjourn the meeting at 7:51 p.m.

AYES: E. Cassidy, J. Dilles, D. Engfer, A. Franklin, R. Moran, D. Pollock, R. Stiles, L. Henry, C. Perri NOES: None ABSTAIN: None ABSENT: J. Leopold, B. McPherson

APPROVED BY: Chris Perri, Chair Date ATTEST: Angela Franklin, Secretary Date

2.1-2


Santa Margarita Groundwater Agency Board of Directors Meeting Minutes

Date: August 27, 2020 Time: 5:30 p.m. Location: Remote Access Only

The County of Santa Cruz and the State Governor had issued shelter-in-place orders that were in effect during

the time of this meeting. In accordance with these orders, the Santa Margarita Groundwater Agency conducted its August Board of Directors meeting in an exclusively remote-access format.

1. CONVENE MEETING

1.1 Call to Order and Roll Call Chair Perri called the meeting to order at 5:32 p.m.

Directors (Alternates acting as voting Directors shown in italics): E. Cassidy, J. Dilles, D. Engfer, A. Franklin, B. McPherson, R. Moran, D. Pollock, R. Stiles, L. Henry, C. Perri Alternates (Present as non-voting observers): B. Ekwall, D. Lind Staff: C. Blanchard, P. Harmon, R. Menard, J. Ricker, S. Ryan, N. Wallace Others: D. Ceppos, G. King, C. Neill, T. Rein


The Board discussed removing the item “Approach for Developing Minimum Thresholds, Measurable Objectives, and Undesirable Results for Depletion of Interconnected Surface Water”. Staff responded to questions.

MOTION: Henry/Cassidy to remove and reschedule the item “Approach for Developing Minimum Thresholds, Measurable Objectives, and Undesirable Results for Depletion of Interconnected Surface Water” (4.1.3).

AYES: D. Engfer, R. Moran, L. Henry, C. Perri NOES: E. Cassidy, J. Dilles, A. Franklin, B. McPherson, D. Pollock, R. Stiles ABSTAIN: None ABSENT: J. Leopold

1.3 Oral communications on items not on the Agenda

One public comment was heard.

Two comments were heard from individual Directors.

2.2-1

2. ADMINISTRATIVE BUSINESS

None

3. CONSENT AGENDA

None

4. GENERAL BUSINESS

4.1 Informational Session – Groundwater Sustainability Plan (GSP) Elements 4.1.1 GSP Roadmap – August 27, 2020

No comments were received on this item.

4.1.2 Surface Water Technical Advisory Group Meeting

S. Ryan presented information from the Surface Water Technical Advisory Group meeting and responded to questions.

J. Dilles and D. Pollock reported on the Surface Water Technical Advisory Group meeting.

One public comment was heard.

4.1.3 Sustainable Management Criteria for Interconnected Surface Water, Degraded Groundwater Quality, and Chronic Lowering of Groundwater Levels (Dave Ceppos [California State University, Sacramento], Georgina King [Montgomery & Associates], and Chelsea Neill [Balance Hydrologics])

- Approach for Developing Minimum Thresholds, Measurable Objectives, and Undesirable Results for Depletion of Interconnected Surface Water

- Approach for Developing Undesirable Results for Degraded Groundwater Quality

- Proposed Minimum Thresholds and Measurable Objectives for Chronic Lowering of Groundwater Levels

- Contents of Section 2 On Plan Area and Basin Setting

C. Neill presented information on the proposed approach for developing minimum Thresholds, Measurable Objectives and responded to questions. D. Ceppos facilitated a conversation the Board, staff, and members of the public.

Four public comments were heard.

Staff requested Director input statements on minimum thresholds, measurable objectives, and undesirable results for depletion of interconnected surface water be emailed to N. Wallace by close of business on September 10th.

G. King presented information on developing undesirable results definitions for degraded groundwater quality. D. Ceppos facilitated a conversation the Board, staff, and members of the public.

Staff requested Director input statements on undesirable results for groundwater quality be emailed to N. Wallace by close of business on September 10th.

Three public comments were heard

2.2-2

G. King presented information on the draft section 2 of the GSP and responded to questions.

Staff advised that the draft section 2 of the GSP will be provided to the board in the near future with the substantial comments related to the content from the board to staff requested back within 2 months following the distribution of the draft document. Staff will compile the comments and present them to the Board in the November/December meeting.

5. STAFF REPORTS

None

6. DIRECTORS REPORTS

None

7. FUTURE ITEMS

- Records Retention Policy

- Financial Controls for Borrowing Money

Informational Sessions

- Groundwater Sustainability Plan Elements

8. INFORMATIONAL ITEMS

- None

9. EVENTS CALENDAR

- Groundwater Resources Association of California Third Annual Western Groundwater Congress, September 14 – September 17, 2020 Virtual Event

10. ADJOURNMENT

MOTION: Engfer/Stiles to adjourn the meeting at 8:33 p.m.

AYES: E. Cassidy, J. Dilles, D. Engfer, A. Franklin, B. McPherson, R. Moran, D. Pollock, R. Stiles, L. Henry, C. Perri

NOES: None ABSTAIN: None ABSENT: J. Leopold

2.2-3

APPROVED BY: Chris Perri, Chair Date ATTEST: Angela Franklin, Secretary Date

2.2-4

Santa Margarita Groundwater Agency Board of Directors Agenda Report __________________________________________________________________________

To: Board of Directors

Date: September 24, 2020

Item: General 4.1

Subject: Status of Projects and Management Action Development for the GSP

SUMMARY

Recommendation: Receive information and provide input.

Fiscal Impact: None

BACKGROUND

Projects and management actions (PMAs) are needed in the Santa Margarita Basin to 1) improve water supply reliability and resiliency for San Lorenzo Valley Water District (SLVWD), Scotts Valley Water District (SVWD), City of Santa Cruz, and private well owners; and 2) to achieve the sustainability goals of the SMGWA. Any project implemented by the SMGWA or others cannot cause undesirable groundwater conditions that prevent achievement of basin sustainability by 2042. This Agenda Report outlines what staff has been working on to develop PMAs, what work still needs to be done to include PMAs in the GSP, and longer-term efforts to get to project implementation.

DISCUSSION

Staff from the SLVWD, SVWD, County of Santa Cruz, and City of Santa Cruz have held two work sessions to focus on identifying the suite of projects to evaluate for possible inclusion in the GSP that collectively will help the Basin achieve sustainability. The goal of these sessions was to examine what we can do regionally that will result in win-win-win solutions to benefit the individual agencies’ and private well owner water supply security, the GSP sustainable management criteria, and the environment. The project matrix (Attachment 1) outlines various solutions that have been proposed at one time or another by individual agencies focusing on their specific needs – usually with a water supply emphasis. Once compiled, projects were reviewed to determine which ones have enough interest and potential to prioritize for further analysis. The highest priority projects were then discussed together in order to identify synergies and conflicts with each other, and with the goals of the SMGWA.

4.1-1

The next step will be to model prioritized projects against baseline conditions (no projects) and the minimum thresholds to determine if the projects, as they are currently defined, are sufficient to achieve sustainability as defined by the Board. If it appears that more or different projects are required, we can go back to the matrix or work to develop new ideas. In addition to just looking at sustainability through the model, we are working with Water Systems Consulting, a subconsultant to Montgomery & Associates, to evaluate the projects from a financial perspective as well as creating realistic timelines for project implementation. This involves a thorough review of expected costs to ensure that all the expenses are included and in a comparable way. There may be multiple approaches to achieve sustainability so having accurate, comparable costs and timelines will help the Board ultimately guide the course the SMGWA will take. The process to go from where we are now to the GSP and all the way through to implementation is outlined in the two flowcharts provided (Attachment 2).

Submitted by,

Sierra Ryan Georgina King Water Resource Planner Lead GSP Consultant County of Santa Cruz Environmental Health Montgomery & Associates Health Services Agency

Attachments: Attachment 1 – Matrix of Potential Projects Attachment 2 – Project and Management Actions Flowcharts Attachment 3 – Projected Timeline for PMA Development and Incorporation in to the GSP

4.1-2

SMGWA Project and Management Action List

Evaluate for GSP Inclusion

How to model Implementation Phase

Source of Water Project/ Program Agency/ies Explanation Constraints Status Benefits Provided Relative Cost per AF/ Source Reliability/ Volume of Water

YES included in water demand

Implemented/ Ongoing *Potential for additional conservation to be achieved

Existing Sources Water Use Efficiency SVWD Implement various programs to maximize the efficient use and minimize water waste: Think Twice Water Use Efficiency Program, Rebate Program, Water Waste Policy, i‐Meters/WaterSmart Customer Engagement Portal

No significant constraints. •SVWD average system demand has been reduced from 178 gpcd in 2000 to 95 gpcd in 2019, average residential demand from 116 r‐gpcd to 60 r‐gpcd. On track to meet the state target of indoor residential use of 55 r‐gpcd by 2025 and 50 by r‐gpcd by 2030. •Es mated annual water savings from Think

Twice Program 470,000 in 2019. •i‐Meter installa on at 80% with planned

completion in Dec 2020.

•Reduc on in groundwater pumping reduces the lowering of groundwater levels. • +GWL in Lompico; +GWS in Lompico

$/high/


Implemented/ Ongoing *Potential for additional conservation to be achieved

Existing Sources Water Use Efficiency SLVWD Reduce demand through increasing the efficiency of water use by existing and future water users

No significant constraints. • District customers continue to demonstrate commitment to ongoing conservation efforts, maintaining at least a 15‐22% reduction in yearly water usage from 2013 consumption levels.• In Fiscal Year 2017/2018 the District issued 46 rebates with an estimated water savings of 630,044 gallons. • In compliance with SB555, SLVWD has been conducting and submitting water loss audit reports to the Department of Water Resources (DWR). SLVWD has been improving its audit score every year from 49 in 2016 to 51 in 2017.• Educational outreach is contacted through social media, newsletters and mailers to promote conservation.

•Reduc on in groundwater pumping reduces the lowering of groundwater levels •+GWL in Lompico and Santa Margarita; +GWS

in Lompico and Santa Margarita; +DISW

$/high/


Implemented/ Ongoing

Existing Sources Water Use Efficiency SCWD Reduce demand through increasing the efficiency of water use by existing and future water users

No significant constraints. Although having hardened demand to the extent SCWD has will limit the amount of additional conservation savings available as well as limit ability to curtail during drought.

The City’s 2015 Urban Water Management Plan documents the current system wide gallons per capita per day (gpcd) of 70, with a residential gpcd of 43. For 2035 the projected system wide gpcd is estimated to be 80, with a residential gpcd of 46. The current (2019) system wide gallons per capita per day (gpcd) of 75 with a residential gpcd of 46. The 2015 UWMP has the forecast of demand including the following: for 2035 the projected system wide gpcd is estimated to be 78, with a residential gpcd of 49.

•Reduces the City's dependence on baseflow from the Santa Margarita basin.

$/high/


Planned Existing Sources Water Use Efficiency SVWD/SLVWD

Additional projects? Could also be included as part of the demand projections as part of the baseline.

Need to be transparent about the relationship between efficiency and growth.

Attachment 1

WORKING DRAFT

4.1-3






Existing Sources Water Use Efficiency County Reduce demand through increasing the efficiency of water use by existing and future water users

The County has no ratepayers and therefore is not able to provide rebates, relying on State rebate programs and grants to offer incentives.

The County participates in the Water Conservation Coalition of Santa Cruz County to provide outreach and education to residents.The County requires source metering and reporting of monthly usage on all public water systems with 5 or more connections. County staff will offer well soundings to private well owners who want to see if their water levels have changed.The County’s water conservation program includes the following elements: •Enforcement of an ordinance on all residen al

users prohibiting wasteful uses of water. •Requirement for replacement of inefficient

toilet and showerheads at time of property sale. •Implemen ng building code requirements for

efficient fixtures for all new construction and remodels. •Requiring water conserva on forms as part of

any new well permits for wells expected to use over 2 AFY.

•Reduc on in groundwater pumping reduces the lowering of groundwater levels. •+GWL in all aquifers; +GWS in all aquifers.

+DISW

$/high/

YES to be added in only 3 existing locations


Stormwater Stormwater Recharge and Low Impact Development

SVWD Where feasible, install small to medium scale (10 acre feet/year up to 1000 acre feet/year/site) facilities to capture storm water and recharge more shallow zones of aquifers through surface spreading and/or constructed dry wells.

•The scale of recharge DSWMAR may be a constraint to achieving mely recharge of the SMGWB •Topographic, ground cover and local vegeta on, and surface and sub‐surface

geology/hydrogeology present significant constraints for siting DSWMA. •DSWMAR introduces water to the upper aquifers and most municipal

pumping draws from deeper levels. Depending on the configuration of aquifers, DSWMAR may never reach the aquifers drinking water is being drawn from.

In the last decade three stormwater infiltration systems have been constructed in Scotts Valley by SVWD and other parties. SVWD monitors all three systems, the combined infiltration was 83 AF over Water Years 2018‐2020

•+GWL in Santa Margarita; +GWS in Santa Margarita; +DISW.

$$$$$/low/

YES use surface water projections from CC to figure out surface water availability and then needed gw pumping


Surface Water/ Groundwater

Conjunctive Use SLVWD Optimizes the use of surface water and groundwater in the North System to utilize stream flows while they are high and groundwater during low flow times, leaving more water in the streams for fish.

No significant constraints. SLVWD has been using Conjunctive Use in the North System for decades.

•Reduc on in GW pumping when SW is available •+GWL in Santa Margarita; +GWS in Santa

Margarita; +DISW. •Needs to consider the impacts of increased

groundwater pumping when surface water is less available.

$/medium/

YES Use Nicks work? Use surface water projections from CC to figure out surface water availability and then needed gw pumping

Studying Surface Water/ Groundwater

Conjunctive Use SLVWD Optimizes the use of currently available sources using systeminterties and potential capacity enhancements; achieves Pasatiempo area in‐lieu recharge by substituting excess North and Felton diversions for groundwater pumping.

•Fall Creek is currently limited by the water right place of use to the town of Felton. •CEQA has not been completed for rou ne water transfers

Funding from the Wildlife Conservation Board is being used to work on a Conjunctive Use Plan that will provide the legal and environmental compliance for this type of project.

•Reduc on in GW pumping when SW is available •+GWL in Lompico; +GWS in Lompico •Needs to consider the impacts of increased


$$/medium/

YES reduce spring gw demand by 313AFY. Need to find out from SLVWD which wells will not be pumped. Need to find out if this occurs every year

Planned *possible use for ASR?

Surface Water ‐ Reservoir

Conjunctive Use SLVWD/ SCWD

SLVWD exercises their contract with the City of Santa Cruz to import 313 AFY from Loch Lomond for In‐Lieu Recharge

•Infrastructure not in place to transfer the water •Water treatment could be challenging for SLVWD •Timing is important

Funding from the Wildlife Conservation Board is being used to work on a Conjunctive Use Plan that will provide the next steps for this project.

•Reduc on in GW pumping when SW is available •+GWL in Lompico; +GWS in Lompico. •Needs to consider the impacts of increased


$$/high/

YES use UWMP projections of recycled water use as a part of total demand


Recycled Wastewater

Non‐Potable Reuse (NPR)

SVWD/ City of SV

Substituting potable water with recycled water for irrigation and temporary construction uses

•Limited use (irriga on and temporary construc on) •Permi ed use does not allow single family residen al parcels •Cost and space constraints for conver ng mul ‐unit residen al complexes

because all units need backflow devices installed •Dual system maintenance more costly (non‐efficient) in long run •Recycled water distribu on mains cover limited area, too costly and

impractical to extend if not supported by a large number of users/customers

Recycled water deliveries commenced in 2002. Through 2019 approximately 2,500 AF has been produced and distributed. Historical maximum recycled water demand was 200 AFY in 2013 (42 customers). In WY 2019 the demand was 174 AFY (56 customers). All new connections that meet permit requirements are required to use recycled water for irrigation purposes if feasible.

•Reduc on in groundwater pumping reduces the lowering of groundwater levels. •+GWL in Lompico and Butano; +GWS in

Lompico and Butano

$$/high/

Attachment 1

WORKING DRAFT

4.1-4




YES Studying Stormwater

Stormwater Recharge and Low Impact Development

SVWD/County

•Where feasible, install small to medium scale (10 acre feet/year up to 1000 acre feet/year/site) facilities to capture storm water and recharge more shallow zones of aquifers through surface spreading and/or constructed dry wells. •Possibly focus on Lockhart Gulch area

where stormwater runoff is currently diverted.

•The scale of recharge DSWMAR may be a constraint to achieving mely recharge of the SMGWB •Topographic, ground cover and local vegeta on, and surface and sub‐surface

geology/hydrogeology present significant constraints for siting DSWMA. •DSWMAR introduces water to the upper aquifers and most municipal

pumping draws from deeper levels. Depending on the configuration of aquifers, DSWMAR may never reach the aquifers drinking water is being drawn from.

•UCSC Professor Andrew Fisher has ini ated work on this approach working with land owners in the Pajaro Valley Water Management Agency on several surface spreading projects and has good data about the effectiveness of this approach given the right surface and subsurface hydrogeologic conditions.

•Benefits dependent on loca on or projects; most likely to benefit the Santa Margarita •+GWL in Santa Margarita; +GWS in Santa

Margarita; +DISW; ?GWQ. $$/low/YES Use Nicks work?

Use surface water projections from CC to figure out surface water availability and then needed gw pumping

Studying Surface Water In Lieu Recharge (passive recharge) and water transfers

SLVWD/SVWD

Provide treated surface water from the SLVWD sources including Loch Lomond to off‐set some or all of the Scotts Valley Water District’s wet season demand and rebuild groundwater resources by eliminating or reducing pumping during some part of the year.

•Availability of the surface water •SVWD limited winter demand •Poten al water quality issues from mixing surface and groundwater in the

pipes •Fall Creek, which is the nearest surface water source to the SVWD, is currently

limited by the water right place of use to the town of Felton

•The County, City of Santa Cruz, San Lorenzo Valley Water District, and Scotts Valley Water District continue to collaborate on a Memorandum of Agreement to work together on exploring conjunctive water use options in the San Lorenzo Watershed and Santa Margarita Groundwater Basin. These efforts will explore many ways to utilize excess winter surface water when available to increase groundwater storage and water supply reliability and increase dry season stream flow. •Nick Johnson studied this in concept in the

Water Availability Assessment. Results are suitable for a planning‐level evaluation of conjunctive use alternatives, i.e., to help qualify fundamental differences between alternatives. These scenarios are simulated under optimal,

•Reduc on in GW pumping when SW is available •+GWL in Lompico; +GWS in Lompico

$$/medium/

YES add new well and reduce pumping at QH wellfield

Studying Groundwater Pumping redistribution

SLVWD Spreading out the pumping in the Quail Hollow Wellfield

Would be a higher priority if there is a sustainability link with the depletion of surface water

YES use already modeled ASR or something else?

Studying Surface Water Aquifer Storage and Recovery (active recharge)

SCWD Create an underground reservoir of stored treated surface water using available winter flows (above those required for ongoing operations, water rights, and fish flows). Stored water would provide drought supply for Santa Cruz and could be designed with additional capacity to contribute to the restoration of the Basin and provide drought storage for Santa Cruz.

•The technical feasibility of storing and retrieving stored water from the Basin may be a constraint. Groundwater modeling and pilot ASR testing is ongoing to quantify physical limitations of the basin (capacity to absorb and retain water) as well as water quality issues that may occur by introducing surface water in to groundwater. •There is no exis ng infrastructure to deliver available water to the Basin and

then potential injection wells beyond existing production wells in the Mid County Basin. •Availability of appropriate real property parcels or rights of way for the

development of necessary wells and delivery infrastructure may be a constraint. •The City’s need to build drought supply through a combina on of passive

and/or active recharge could result in significant future withdrawals from the basin that may interfere with the timeframe or even ultimate success of reaching basin recovery goals. •Long term reliability of surface water as a supply may be an issue if climate

change results in some shift in the amount or pattern of precipitation and/or if multi‐year drought conditions occur.

•The City of Santa Cruz is working to assess the feasibility of injecting treated drinking water from its surface water sources into regional groundwater aquifers. Phase I of the work is nearing completion although groundwater modeling will be ongoing; Phase II includes pilot testing injection and extraction in the Mid‐County Basin •Plans are being developed to pilot in the Santa

Margarita Basin in FY2023 •Informa on generated by these evalua ons will

be used to determine the degree to which ASR is a feasible part of the City’s strategy to improve the reliability of its water supply and will be used as part of the City’s planned supplemental water supply decision process. •The City has modified the ini al work plan in to

three phases: ASR in the mid‐county basin using existing infrastructure, evaluation and implementation of additional ASR wells in either the mid‐county and/or Santa Margarita

•Increasing groundwater levels when surface water is available. •Benefits dependent on loca on and depth of

the injection wells •+GWL in Santa Margarita or Lompico; +GWS in

Santa Margarita or Lompico; +DISW; ?GWQ. •Needs to consider the impacts of increased


$$$/high/

Attachment 1

WORKING DRAFT

4.1-5




YES Concept Surface Water In Lieu Recharge (passive recharge) and water transfers

Potentially All Provide treated surface water from the City’s

San Lorenzo River and North Coast sources to off‐set some or all of the wet season demands of Scotts Valley Water District to rebuild groundwater resources by reducing pumping during some part of the year. Water could also be transferred to parts of the San Lorenzo Valley Water District South System which is solely reliant on groundwater.

•Volume of the City’s available water is limited due to fish flows, and water right Place of Use restrictions until the Water Rights project is complete. •Excess water from the North Coast sources is being u lized in the Santa Cruz

Mid‐County Basin via a pilot water transfer project with SqCWD •Water quality issues in the SqCWD system involving the mixing of treated

drinking water from surface water and groundwater sources were identified in bench top testing; the pilot testing is being used to validate. •Discussions with neighboring agencies are ongoing; there are no addi onal

pilot test planned at this time with the pilot agreement with SqCWD expiring at the end of CY2020. •Poten al volume of wet season demand that could be off‐set by providing

treated surface water is a limiting factor and may not provide for restoration of the basin within a desired time frame. •No inter e exists between the Santa Cruz Water Department and either the

SLVWD or SVWD.

•Modeling and other studies are needed to determine limitations of the City and Districts infrastructure and identify where improvements may be needed to convey additional water. •The County, City of Santa Cruz, San Lorenzo

Valley Water District, and Scotts Valley Water District continue to collaborate on a Memorandum of Agreement to work together on exploring conjunctive water use options in the San Lorenzo Watershed and Santa Margarita Groundwater Basin. These efforts will explore many ways to utilize excess winter surface water when available to increase groundwater storage and water supply reliability and increase dry season stream flow. •Inter es with all agencies are being evaluated in

the Water Rights Project at a programmatic level.

•Reduc on in GW pumping when SW is available •+GWL in Santa Margarita; Lompico and

Butano; +GWS in Santa Margarita; Lompico and Butano; +DISW; ?GWQ.

$$$/high/

YES El Pueblo site injection at asumed <0.2 MGD per well, at 3 wells (1 new and 2 existing 11A and 11B) during winter season only.

Concept WW from Scotts Valley purified at a new Advanced Water Purification Facility (AWPF) at El Pueblo Site

Scotts Valley Led Local, Seasonal SMGB Indirect Potable Reuse (IPR) – Groundwater Replenishement Reuse Project (GRRP)

SVWD,City of SV

•Maximize the poten al of Sco s Valley wastewater by improving secondary treatment at SV‐WRF •Purify effluent at a new 0.5 MGD capacity

AWPF (potentally at El Pueblo Site) •Purified effluent woud be conveyed to

existing El Pueblo wells and an additional well ro recharge the Lompico aquifer in SMGB. •Produce 250 AFY of purified water

seasonally for recharge into SMGB •Brine discharge via Santa Cruz ou all

•No technological constraints. The full advanced treatment (FAT) process has a proven track record of performance, clearly defined regulatory requirements and are already widely in use in California and elsewhere. •Public percep on related to perceived public health issues associated with

using waste water as a source supply for drinking water •Groundwater modeling to assess available capacity in the groundwater basin

and ability to meet regulatory travel times. •Water quality tes ng to assess poten al water quality impacts to the basin

and to meet regulatory reuqirements •Uncertain reliability of source water (SV Wastewater Treatment Facility

requires improvements to produce consistent secondary effluent for purificiation) and limited amount of source water (wastewater) due to relatively small population at Scotts Valley •Brine disposal limits AWPF year‐round opera on (treatment only in winter

months) due to SV WRF ability to accept/process brine and impacts of brine to water source for Pasatiempo Golf Course. Seasonal operation would limit recharge to 250 AFY purified water, with production only during the winter season.

•2017 ‐ Ini al GRRP feasibility study for SVWD completed under a SWRCB planning grant •2020 Recycled Water Alterna ves Evalua on

study (SVWD/Kennedy Jenks) compared regional project scenarios and conducted conceptual evaluation of a broad range of criteria (presented to SVWD Board on 9/14/2020). •CEQA process currently on hold due to

uncertainty with source water reliability and SV WWTP ability to accept/process brine.

•Increasing water levels sesonally (limited recharge of groundwater assumed in the winter months only until a solution for brine management is developed) •Benefits limited to amount of purified water

that can be produced (limited source of water) •Recharge of GW levels in Lompico aquifer

$$$$/medium/

YES El Pueblo site injection at asumed <0.2 MGD per well, at 3 wells (1 new and 2 existing 11A and 11B) year round plus additional NEW wells (TBD) for excess recharge capacity.

Concept WW from Santa Cruz WWTF purified at an expanded Pure Water Soquel (PWS) AWPF at the Chanticleer Site

Year‐Round SMGB IPR‐GRRP thru Partial expansion of PWS Project

SVWD, SqCWD, Santa Cruz,SLVWD?

•Expand the capacity of the PWS project to provide advanced purification of tertiary non disinfected effluent from SC WWTF at the new 0.8 MGD capacity AWPF at the Chanticleer site. •Purified effluent woud be conveyed to SV El

Pueblo site for final conditioning and injection at El Pueblo wells and additional wells ro recharge the Lompico aquifer in SMGB. •Produce 750‐900 AFY of purified water for

recharge into SMGB •Brine discharge via Santa Cruz ou all

•No technological constraints. The FAT techniques and processes have a proven track record of performance, clearly defined regulatory requirements and are already widely in use in California and elsewhere. •Public percep on related to perceived public health issues associated with

using waste water as a source •Groundwater modeling required to assess available capacity in the

groundwater basin and ability to meet regulatory travel times. •Water quality tes ng is required to assess poten al water quality impacts to

the basin and to meet regulatory reuqirements •Concept for PWS expansion capacity was ini ally intended for the Mid‐County

Basin •Dependability on other agencies to supply the source water (i.e. Santa Cruz

and SqCWD). •Complex mul ‐agency partnerships/Ins tu onal Agreements required (i.e.

cost sharing, operational agreements, etc.) •Lack of conveyance network with other agencies to sell excess recharged

water. •Considerable capital and O&M cost for treatment of purified water and

conveyance to SV

•2020 Recycled Water Alterna ves Evalua on study (SVWD/Kennedy Jenks) compared regional project scenarios and conducted conceptual evaluation of a broad range of criteria (presented to SVWD Board on 9/14/2020).

•Increasing water levels year round •Benefits dependent on loca on and depth of

the injection wells •Recharge of GV levels in Lompico aquifer and

SMGB •Regional par cipa on brings higher flows and

benefit of shared infrastructure •Economies of scale from implementa on of a

larger project

$$$/high/

Attachment 1

WORKING DRAFT

4.1-6




YES El Pueblo site injection at asumed <0.2 MGD per well, at 3 wells (1 new and 2 existing 11A and 11B) year round plus additional NEW wells (TBD) for excess recharge capacity (likely near Hanson Quarry).

Concept WW from Santa Cruz purified at an expanded PWS AWPF at the Chanticleer Site

Year‐Round SMGB IPR‐ GRRP thru Full expansion of PWS Project

SVWD, SqCWD, Santa Cruz,SLVWD?

•Maximize the expansion of the PWS project to provide advanced purification of tertiary non disinfected effluent from SC WWTF at the new 1.6 MGD capacity AWPF at the Chanticleer Site. •Purified effluent woud be conveyed to SV El

Pueblo site for final conditioning and injection at El Pueblo wells and additional wells ro recharge the Lompico aquifer in SMGB. •Produce 1,500 AFY of purified water for

recharge into SMGB •Santa Cruz to convey extracted water to

Newell Creek Pipeline •Brine discharge via Santa Cruz ou all

Same as above •The 2020 Recycled Water Alterna ves Evaluation study (SVWD/Kennedy Jenks) did not look at utilizing the full expansion capacity of the PWS AWPF. •The City of Santa Cruz is currently conduc ng a

Phase 2 Recycled Water Feasiblity Study that is ongoing and is incorporating the PureWaterSoquel project into the alternative feasibility analyses as appropriate.

•Increasing water levels year‐round •Benefits dependent on loca on and depth of

the injection wells •Recharge of GW levels in Lompico aquifer and

SMGB •Regional par cipa on brings higher flows and


larger project

$$/high/

YES Potential Sites identified in Santa Cruz Regional RWFPS (TM #2b), also consider additional sites near/at Hansen Quarry and El Pueblo site injection wells.

Concept WW from Santa Cruz purified at a new AWPF

Maximize SMGB IPR‐ GRRP thru new AWPF

SCWD, SVWD, SLVWD

• Maximize IPR via GRR in SMGB using up to 4.0 mgd of source water from the SC WWTF (secondary/tertiary). • New 3.2 MGD capacity AWPF •Purified effluent woud be conveyed to a

Scotts Valley site for final conditioning and injection at El Pueblo wells and additional wells near Hanson Quarry ro recharge the Lompico aquifer in SMGB. •Produce 3,500 AFY of purified water for

recharge into SMGB• Use existing/new extraction wells to serve City, SVWD and SLVWD • Conveyance of source water, extracted water and brine btw Santa Cruz and Scotts Valley

• Secondary or Tertiary water from SC WWTF conveyed to Scotts Valley, depending on availble space at SC WWTF and preferred WQ prior to advanced treatment• Identification of a suitable site in Scotts Valley to construct a 4.0 mgd AWPF (El Pueblo site is too small, ideally new location near recharge areas) •Public percep on related to perceived public health issues associated with

using waste water as a source supply for drinking water •Groundwater modeling to assess available capacity in the groundwater basin

and ability to meet regulatory travel times. •Water quality tes ng to assess poten al water quality impacts to the basin

and to meet regulatory reuqirements• City would need new extraction wells and conveyance to Newell Creek Pipeline• New brine line from AWPF to Santa Cruz outfall (remaining wastewater needs to be able to provide sufficient blending to meet outfall discharge requirements)

•The 2018 Santa Cruz Regional Recycled Water Faciliteis Planning Study (Kennedy Jenks) completed under a SWRCB planning grant looked at this alterantive •The City of Santa Cruz is currently conduc ng a

Phase 2 Recycled Water Feasiblity Study that is ongoing and is developing alternatives from Phase 1 that appeared feasible.

•Increasing water levels year‐round •Benefits dependent on loca on and depth of

the injection wells •Recharge of GW levels in Lompico aquifer •Regional par cipa on brings higher flows and


larger project

$$/high/

YES n/a Concept Santa Cruz WWTF purified at a new AWPF

IPR via Reservoir Water Augmentation at Loch Lomond

SCWD and SLVWD? And possibly others

•Reservoir augmenta on with purified water in Loch Lomond for blending and storage, to be conveyed to the GHWTP and enter the City's potable water distribution system. •Provide water for City to meet its drought

supply needs •Poten al to allow long term water service

from surface water sources to the neighboring water districts, thus substantially reducing or eliminating groundwater pumping in the Santa Margarita Groundwater Basin.

•There is a regulatory parthway for reservoir water agumenta on projects and though no projects are currently permitted in California there are three projects in various stages of planing, design and contruction. •Requires mee ng reservoir reten on and dillu on mes. •Facility opera on would be limited when the reservoir is full from natural

runoff, which is the lowest cost and lowest energy supply. •Climate change and resiliency work for City (by UMass) in progress to

understand true benefit of supply in dry years) •Would require the Santa Cruz Water Department to operate Loch Lomond

differently in the future •Public percep on related to perceived public health issues associated with

using waste water as a source supply for drinking water



•Benefits mirror in‐lieu recharge but are not seasonal in nature •Reduc on in GW pumping; loca ons

depending on which Districts partner on the project

$$$$/high/

YES n/a Concept Santa Cruz WWTF purified at a new AWPF

Direct Potable Reuse •Blend purified water with raw water prior to treatment at GHWTP to maximize available beneficial reuse year‐round •Provide water for City to meet its drought

supply needs •Poten al to allow long term water service

from surface water sources to the neighboring water districts, thus substantially reducing or eliminating groundwater pumping in the Santa Margarita Groundwater Basin..

• The report "A Proposed Framework for Regula ng Direct Potable Reuse in California" was released (April 2018), which identifies key research areas to fill the identified knowledge gaps prior to the adoption of water recycling criteria for direct potable reuse through raw water augmentation by December 2023 (per AB 574). • Given the outcome of the framework and interest in potable reuse Statewide,

raw water blending should continue to be tracked as a potential long‐term strategy to maximize reuse and reduce ocean discharge. • Policy issues may include poten al percep on that there are public health

issues associated with using wastewater as a source water for drinking water supplies



•Benefits mirror in‐lieu recharge but are not seasonal in nature •Reduc on in GW pumping; loca ons

depending on which Districts partner on the project •+GWL in Santa Margarita; Lompico and

Butano; +GWS in Santa Margarita; Lompico and Butano; +DISW; ?GWQ.

$$$$/high/

YES n/a Not Pursued Existing Sources Water Use Restrictions

Limit the amount of pumping allowed, charge high usage fees

•Legality •Equity •Enforcement

•While not currently under considera on, SGMA grants the SMGWA the authority to restrict pumping. •Should the SMGWA fail to adopt a GSP, or fail to

reach sustainability, the State Water Board will take this approach.

YES? n/a Concept Existing Sources Consolidation of Private Well into municipal service

If private pumping is impacting surface water resources or GDEs, some of the parcels could be connected to one of the municipal providers

Not currently under consideration

Attachment 1

WORKING DRAFT

4.1-7




Maybe n/a Concept Groundwater Private Well Deepening

Deepening private wells using water from the Santa Margarita formation so that they are drawing water from the Lompico or Butano (depending on location). This would be targeted to private pumping from the Santa Margarita is negatively affecting base flows and no other viable solutions become apparent.

•Cost of projects and who would be required to do it will require extensive research and outreach •While it would benefit the Santa Margarita aquifer and GDEs, the impact to

GWL in the Lompico would have to be tracked.

Not currently under consideration •Reduc on in GW Pumping from the Santa Margarita Basin. •+GWL in Santa Margarita; +GWS in Santa

Margarita; +DISW; ‐GWL in Lompico or Butano; ‐GWS in Lompico or Butano; +DISW.

$$/high/

Attachment 1

WORKING DRAFT

4.1-8

Evaluation at the Individual Project LevelAggregate Project Selection and Evaluation

1. Identify the problem(s) we are trying to solve2. Review of already planned projects, quantify benefits 3. Project parameters are based on best available existing information4. Analyze information and identify data gaps.5. Eliminate projects that are not a good fit

Projects Flowchart- the GSP is Just the Beginning

Concept Evaluation and

Preliminary Feasibility

1. Further evaluation including by groundwater model - look for conflicts and synergies2. Match the solutions with the problems we are trying to solve3. Modify and refine projects, update assumptions

Refine project list based on Feasibility

1. Develop list for GSP2. Establish timeline3. Determine responsible party/parties4. Develop cost estimate to identify funding mechanisms

Finalize Parameters

1. Bench testing water quality if applicable2. Pilot wells (injection and/or extraction)3. Incorporate lessons learned from pilot testing4. Establish project scope, locations, drawings, and construction sequencing5. Provide realistic cost estimate and finalize funding mechanisms

Pilot Testing and Design

1. Water Quality2. Impacts to water rights and other users of water3. Impacts to the environment

CEQA Environmental

Review and Permits

1. Purchase of necessary land/ access agreements2. Implement CEQA and permit requirements3. Construction and construction management

Construction

1. Finalize operations and maintenance plans2. Evaluation and assessment of project outcomes and impacts

Operations and Maintenance

Public Input

Public Input

Timeframe: 1-2 years


We are here

Attachment 2

4.1-9

Evaluation at the Individual Management Action LevelAggregate Management Action Selection and Evaluation

1. Identify the problem(s) we are trying to solve2. Review of existing programs, quantify benefits 3. Management action parameters are based on best available existing information4. Analyze information and identify data gaps.

Management Actions Flowchart- the GSP is Just the Beginning

Concept Evaluation and

Preliminary Feasibility

1. Further evaluation including by groundwater model - look for conflicts and synergies2. Match the solutions with the problems we are trying to solve3. Modify and refine management actions, update assumptions

Refine Management

Action List Based on Feasibility

1. Develop list for GSP2. Establish timeline3. Determine responsible party/parties4. Develop cost estimate to identify funding mechanisms

Finalize Parameters

1. Review likely limited to CEQA exemption or Negative Declaration2. Permits and adjustments to water rights might be required

CEQA Environmental

Review and Permits

1. Implementation of Activities2. Periodic evaluation of management actions and impacts3. Modify, update, and refine

Implementation

Public Input

Public Input



We are here

Attachment 2

4.1-10

Attachment 3

Projected Timeline for PMA Development and Incorporation in to the GSP

09/2

020

10/2

020

11/2

020

12/2

020

01/2

021

02/2

021

03/2

021

04/2

021

05/2

021

06/2

021

07/2

021

Staff bring reduced project list to BoardPMAs to be modeled finalizedModel PMAsComparison of preferred projects (time, cost, benefits)Prepare final PMAs, costs, cost share memoBoard meeting to approve PMAs and cost share proposalGSP Section 4: Projects & Management Actions drafted for internal reviewSection 5: GSP Implementation drafted for internal reviewCompile Draft GSPDraft GSP to Board; Incorporate any edits by 7/1/2021Final Draft GSP Prepared

4.1-11

4.2-1

August September October NovemberMeeting Content Covers:

• Thresholds, objectives, & undesirable results for groundwater quality, groundwater levels, and basin surface water

• Groundwater modeling results

• Climate change scenarios

• Significant & unreasonable conditions, thresholds, & objectives for groundwater quality, levels, & interconnected surface water

• Approach for developing sustainable management criteria for groundwater storage

• Basin management actions

• Historic water budget

• Follow up from September

• Project impacts on basin conditions

Actions Needed Regarding :

• No formal actions needed • Minimum Threshold for Nitrate • No formal action needed • No formal action needed

September 24, 2020GSP Deadline: January 31, 2022

Development ofProjects

Development ofSustainability Measures

Focus Areas Groundwater Model Data Management System Surface Water Tech Advisory Group Draft GSP

Progress 90% 10% 50% 40%4.2-2

Common Acronyms and Abbreviations

ACWA-JPIA ACWA Joint Powers Insurance Authority

AF Acre Foot

AFY Acre Foot per Year

BMP Best Management Practices

CD Certificate of Deposit

CEQA California Environmental Quality Act

DHS Department of Health Services

DMS Data Management System

DSW Depletion of Interconnected Surface Water

DWR Department of Water Resources

EIR Environmental Impact Report

GASB Governmental Accounting Standards Board

GSP Groundwater Sustainability Plan

GWL Chronic Lowering of Groundwater Levels

GWQ Degraded Groundwater Quality

GWS Reduction of Groundwater Storage

IRWM Integrated Regional Water Management

JPA Joint Powers Agreement

LAFCO Local Agency Formation Commission

LID Low Impact Development

MGD Million Gallons per Day

MGY Million Gallons per Year

MO Measurable Objectives

MT Minimum Thresholds

O&M Operations and Maintenance

PHG Public Health Goal

PPB Parts Per Billion

RFP Request for Proposals

RMP Representative Monitoring Point

RWMF Regional Water Management Foundation

RWQCB Regional Water Quality Control Board

SCWD Sant Cruz Water Department

SDWA Safe Drinking Water Act

SGMA Sustainable Groundwater Management Act

SI Sustainability Indicator

SLVWD San Lorenzo Valley Water District

SMC Sustainability Management Criteria

SMGWA Santa Margarita Groundwater Agency

SqCWD Soquel Creek Water District

SVWD Scotts Valley Water District

SW Surface Water

SWRCB State Water Resources Control Board4.2-3

Santa Margarita Groundwater Agency Board of Directors Agenda Report __________________________________________________________________________

To: Board of Directors

Date: September 24, 2020

Item: General 4.2.2

Subject: Sustainable Management Criteria for Depletion of Interconnected surface Water, Degraded Groundwater Quality, Chronic Lowering of Groundwater Levels, and Reduction of Groundwater Storage

SUMMARY

Recommendation: Receive information and provide input; approve draft minimum thresholds for groundwater quality relating to nitrates.

Fiscal Impact: None from this action.

DISCUSSION

Dave Ceppos (California State University, Sacramento), Chelsea Neill (Balance Hydrologics), and Georgina King (Montgomery & Associates) will lead presentations and discussions on sustainable management criteria for depletions of interconnected surface water, degraded groundwater quality, chronic lowering of groundwater levels, and reduction of groundwater in storage.

Presentation slides and supplemental material for these items will be made available at www.smgwa.org.

Introduction and Session Review (5 minutes)

a. Undesirable Results for Degraded Water Quality, revisit Minimum Threshold for Nitrate (40 minutes)

b. Minimum Thresholds and Undesirable Results for Chronic Lowering of Groundwater Levels (30 minutes)

c. Significant and Unreasonable Conditions, Minimum Thresholds and Undesirable Results for Depletion of Interconnected Surface Water (40 minutes)

d. Introduction to Reduction of Groundwater in Storage Sustainability Indicator, and Proposed Approaches for Minimum Thresholds and Measurable Objectives (30 minutes)

Submitted by,

4.2.2-1

http://www.smgwa.org/

Piret Harmon

General Manager

Scotts Valley Water District

Attachments: Comments on Undesirable Results (UR) for Degraded Groundwater Quality

Comments on Undesirable Results (UR) for Chronic Lowering of Groundwater Levels

Statement of Significant and Unreasonable Conditions for Depletion of Interconnected Surface Water

4.2.2-2

Santa Margarita Groundwater Agency

Undesirable Results (UR) for Degraded Water Quality 8/27/20

Proposed Approaches

10-year Arithmetic Moving Average

10-year Exponential Moving Average

Input from Directors:

Exponential

/---------------------/

Arithmetic – takes volatility out and increases flexibility

/---------------------/

Arithmetic – reflects longer term trends, water agencies are responsible for water quality immediate and significant changes

/---------------------/

Arithmetic

/---------------------/

Could arithmetic and exponential moving averages methods be combined?

/---------------------/

So many competing / inter-connected considerations: transparency and intelligibility of our measures; responsiveness to meaningful signals; differentiating between daily operational considerations and long-term basin health considerations; etc.

Mindful that, as regards daily operation of these wells, we will be monitoring GW quality on an ongoing basis, I’m somewhat less concerned about the short-term responsiveness of the moving average, and more concerned that it tell the right long-term story.

I’m also quite concerned that, to the extent reasonably possible, we use transparent measures that are easily understood and calculated by civilians.

So, today, I’m on the side of arithmetic moving 10-year average.

/---------------------/

Arithmetic Moving Average preferred.

/---------------------/

4.2.2-3

I support using “some” well over any, and a 10-year simple moving average. I like exponential, but that’s because I’m using the true data to watch trends and make operational decisions. Simple moving average seems more appropriate here.

Input from Others:

Exponential – reflects change in contaminants quicker

Example UR for Degraded Water Quality:

Undesirable results occur if <any/some> of the degraded groundwater quality RMPs’ <10-year exponential/arithmetic averages> exceed their respective minimum thresholds.


Any or 10% if arithmetic averages used. If exponential averages used, then 2 RMPs

/---------------------/

20%

/---------------------/

Use either number or percentage, whichever is smaller.

/---------------------/

RMP’s should be grouped by aquifers. Wells that are detecting contaminants could be temporary switched off (make inactive) until the WQ test improve.

/---------------------/

Mindful that we are looking at a long-term (10-year) trend, and evaluating the impacts of our GSP (PMA results), I’m going to stick with “ANY” - we should not “kill” any wells without mitigation. I recognize that this is a high bar, but who wants to explain to a private or municipal pumper that they need to drill a new well due to our GSP-related activities? We need to take responsibility for the consequences of our actions.

/---------------------/

Suggested refinement of the Definition of Undesirable Results:

Undesirable Results occur if of RMP’s 10-year arithmetic moving average exceed their respective minimum thresholds.

Need a systematic method like the suggestion above to determine the number of exceedances that result in Undesirable Results.

4.2.2-4

Maximize flexibility to avoid Undesirable Results, especially if wells are temporarily relied on more heavily to supply water. Use of a flat percentage may be of limited value because we need to consider the number and geographic distribution of the different pumping centers. For example, if one of the two Quail Hollow wells exceed the MT, it represents a small fraction of the total monitoring wells in the basin but one-half of the wells in the affected well field.

Input from Others:

Allow one well to exceed (20%).

4.2.2-5


Undesirable Results (UR) for Groundwater Levels 8/27/20

Approach for UR for Groundwater Levels

Does the input on UR for degraded water quality apply to chronic lowering of groundwater levels?


Use the same approach that is used for WQ: arithmetic 10-year average. Averaging only represents UR, short term trends can still be detected and should be addressed.

/---------------------/

10-year exponential or 5-year arithmetic

/---------------------/

5-year arithmetic

/---------------------/

Maximize flexibility to avoid Undesirable Results, especially if for wells are temporarily relied on more heavily to supply water. A flat percentage may be of limited value, and it may be necessary to factor in a recovery period (see comment above For example, if one of the two Quail Hollow wells exceed the MT, it represents a small fraction of the total monitoring wells in the basin but one-half of the wells in the affected well field. Also need to factor in a “period of time.” For example, a window for temporary water level declines to recover (like a low water level in the Fall recovering by the following Spring).

Input from Others:

5-year arithmetic

/---------------------/

4.2.2-6


Statement of Significant and Unreasonable Conditions for Depletion of Interconnected Surface Water 8/27/20

Proposed Draft:

Depletion of interconnected surface water occurs where interconnected surface water is depleted due to GSP implementation and/or groundwater use. To be considered significant and unreasonable, the depletions must cause significant adverse impacts to the viability of individual priority species or GDEs or undue financial burden to beneficial users of uses of the surface water.

Input from Surface Water TAG:

Statement replaces vague notion of “significant and unreasonable” with “significant and undue”.

“Undue” should be removed or more clearly defined.

Statement could be more aspirational. For example: “To be considered significant and unreasonable, the depletions must cause undue financial burden to beneficial users or uses of the surface water, or significantly reduce the likelihood of recovery of historic populations of one or more priority species”.


Undue refers to potential impacts to beneficial users.

/---------------------/

Add to “…and/or groundwater use” the following “…and/or groundwater use except groundwater use by de-minimis users”. Private well owners are primary pumpers in SM aquifer and should not be bearing the full responsibility for ensuring sufficient supply for beneficial uses (GDEs).

/---------------------/

Undue is financial lingo, it means unreasonable and therefore covers de-minimis users.

/---------------------/

Undue financial burden applies to beneficial users – not applicable to beneficial uses.

/---------------------/

Supports “undue financial burden to beneficial users of surface water”.

/---------------------/

The word “significant” needs more concrete definition/description.

/---------------------/

“Undue” - sounds like we are going to have a focused discussion on this subject. Recognizing that everything costs money, and that our built environment and infrastructure reflects (in some cases significant) previous investments, I’m starting from something like: “significant or significantly increased, and otherwise avoidable, expenses”.

4.2.2-7

Cannot support a blanket “pass” for de minimis (aka small private) pumpers; this would create a clear moral hazard. We must (1) follow the science (in this case, as regards understanding the impacts of various groundwater uses and users), and (2) fairly and equitably allocate the costs associated with mitigating those impacts consistent with our MOs and PMAs. At the most clinical, mitigation costs related to reduced base flows from the Santa Margarita layer could create a simple choice: either contribute ratably to the mitigations or drill more deeply to get into a layer that doesn’t affect base flows so significantly. I would also note that any ASR-related activities in any of the layers (and most particularly the Santa Margarita) may substantially offset aggregate de minimis pumping.

If we are going to use GW levels as a proxy for changes in base flow, we need to pay particular attention to the location of monitoring wells, to ensure that the calculus will work with validity and reliability. Staff mentioned something about 7 or so additional wells - need to ensure (1) adequate number and (2) appropriate locations. Given that any other approach is (apparently) too difficult or costly to pursue, we should be willing to drill the monitoring wells we need, where we need them, even if at a greater expense than will be covered by State grants.

/---------------------/

It is important to keep the word “undue” in the statements. “Undue” communicates that there is limit to the cost and ensures they do not become excessive, unjustifiable, inappropriate or unreasonable.

Suggest the following refinement to the Statement of S&U

“Depletion of interconnected surface water occurs where interconnected surface water is depleted due to GSP implementation and/or groundwater use. To be considered significant and unreasonable, the depletions must cause undue financial burden to beneficial users of surface- or groundwaters in the Basin or impact the viability of selected priority species or GDEs.”

Using the historical minimum value: What is the ending point for the period of record? The plots show October 2018, but should we consider 2019 or even 2020 data? Perhaps we need to consider data in the upcoming year which will include the consequences of catastrophic events (e.g., fire).

/---------------------/

Approach for developing Minimum Thresholds and Measurable Objectives for Depletion of Interconnected Surface Water: take an average of multiple lowest points over the entire data point set, and then go 1 standard deviation below that.

Input from Others:

SGMA does not give a pass to de-minimis users if they are causing significant adverse impacts.

/---------------------/

Undue is a legal term. Defining “undue financial burden” for all indicators is helpful.

/---------------------/

4.2.2-8

Use an average of historical minimums instead of one single datapoint when determining MT.

/---------------------/

Having only two RMPs poses a potential data gap. Agrees with previous comment about using average of historical minimums for MT.

/---------------------/

I revised the concept of undue financial burden from ADA law and came up with the following rough draft:

Undue financial hardship is any action that fundamentally alters the nature or operation of the business of the member agencies or the beneficial users and is unnecessarily costly, extensive, substantial or disruptive.

When determining whether an action would impose an undue hardship on the member agencies or the beneficial users, the following factors may be considered:

- The nature and net cost of the proposed action

- The overall financial resources available by the member agencies or beneficial users

- The number and location of those who will participate in the proposed action

- The anticipated benefits to be achieved from the proposed action, including relative benefits by geographical area

- Whether disproportionate financial impact is occurring based on certain member agencies or beneficial users

4.2.2-9

Documents

Santa Margarita Groundwater Agency · 24.09.2020 · pursuant to title ii of the americans with disabilities act of 1990, the santa margarita groundwater agency requests that any