framing for calleguas’ comments - background and history

THOMAS L. SLOSSON, PRESIDENT DIVISION 1 ANDY WATERS, SECRETARY DIVISION 3 STEVE BLOIS, DIRECTOR DIVISION 5

ANDRES SANTAMARIA, VICE PRESIDENT DIVISION 4

SCOTT H. QUADY, TREASURER DIVISION 2

SUSAN B. MULLIGAN GENERAL MANAGER

web site: www.calleguas.com

2100 OLSEN ROAD • THOUSAND OAKS, CALIFORNIA 91360-6800 805/526-9323 • FAX: 805/522-5730 April 2, 2018 Keely Royas, Clerk of the Board Fox Canyon Groundwater Management Agency 800 South Victoria Avenue Ventura, CA 93009 Subject: Comments on November 2017 Preliminary Draft Las Posas Valley Basin

Groundwater Sustainability Plan Dear Ms. Royas: Calleguas Municipal Water District (Calleguas) appreciates this opportunity to provide comments to the Fox Canyon Groundwater Management Agency (FCGMA) on the Preliminary Draft Las Posas Valley Basin Groundwater Sustainability Plan Preliminary Draft dated November 2017 (LPVB PDGSP). It is critical that the GSP be based on best available information and best available science, address existing water rights, incorporate existing FCGMA policies, approvals, and agreements, and address stakeholder concerns. Calleguas strongly encourages the FCGMA to consider the comments provided in this letter and incorporate them into its continuing work on the GSP. Addressing the comments raised here and by others into the continuing work will provide a better GSP, which is critical for future basin management. Framing for Calleguas’ Comments - Background and History of Calleguas The following paragraphs provide a brief background and history of Calleguas to provide appropriate context for the comments provided. Calleguas Background and Need for Local Storage By the early 1950s, southern Ventura County aquifers were experiencing declining water levels and increased salinity. Businesses and residents realized that the situation was unsustainable and that water would need to be brought in from outside the area. As a result, Calleguas Municipal Water District (Calleguas) was formed in 1953 as an independent special district by the voters of southern Ventura County for the purpose of providing a safe, reliable water supply. In 1960, Calleguas became a member agency of the Metropolitan Water District of Southern California (Metropolitan), which provides southern California with imported water from the Colorado River via the Colorado River Aqueduct and from northern California via the State Water Project (SWP).

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In the early 1960s, Calleguas built infrastructure to transport and deliver water from Metropolitan to southern Ventura County. Given infrastructure limitations that only allowed imported supply to be delivered through one pipeline through the San Fernando Valley, one tunnel through the Santa Susana Pass, and one pipeline in Simi Valley, Calleguas also built Lake Bard, which could store 10,000 acre-feet to provide water when the imported supplies were shut down for scheduled maintenance or unplanned emergencies. At that time, the service area water demands were approximately 10,000 acre-feet per year so Lake Bard could provide supply for a one year outage. By the early 1990s, water demands had exceeded 100,000 acre-feet per year and Lake Bard could supply only a fraction of potentially needed water supplies during an emergency outage. In fact, after the January 1994 Northridge Earthquake, imported supplies were only available sporadically for 3 months and Lake Bard came very close to going dry. Had the earthquake occurred in summer, portions of the southern Ventura County could have been entirely without water for several weeks.

Las Posas Aquifer Storage and Recovery Project Development

In order to store additional water for use during an outage of imported supplies, in the 1980’s Calleguas began evaluating the feasibility of implementing aquifer storage and recovery (ASR) in the East Las Posas (ELP) basin (then referred to as North Las Posas). In 1991 Calleguas and Metropolitan funded an ASR demonstration project at Ventura County Waterworks Well No. 97. In 1993, Calleguas built a single ASR well in the ELP basin to test the feasibility of the technology. In 1993 CH2M Hill completed a hydrogeologic model and issued a report on the feasibility of implementing ASR in the ELP basin. In October 1993, the Fox Canyon Groundwater Management Agency (FCGMA) adopted Resolution No. 1993-2, A Resolution to Support and Protect Injected and Percolated Water (see Attachment A), which included the following language:

WHEREAS, the injection or percolation of water into the aquifer systems within the FCGMA is consistent with good management practices, benefiting the FCGMA and Ventura County as a whole; and WHEREAS, the injection or percolation of water into the aquifer systems of the FCGMA is essential to meet seasonal and dry year demands and provide protection from other potential water supply emergencies; and WHEREAS, monitoring guidelines for meeting Agricultural and Municipal and Industrial (M & I) standards and control of injected or percolated water will be accomplished by ordinance or in the specific project approval process; and WHEREAS, those ones, agencies and Individuals that invest significant funds to develop storage facilities and comply with the requirements of the FCGMA Ordinance are entitled to recover the water injected or percolated. NOW, THEREFORE IT IS HEREBY PROCLAIMED AND RESOLVED that it is the policy of the FCGMA to support these efforts and will employ its powers to protect injected and percolated foreign water for the various purposes of those agencies, cities and individuals who have injected and percolated water in accordance with the FCGMA regulations and within the boundaries of the FCGMA.

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On February 23, 1994, FCGMA Board approved Calleguas’ installing up to 20 ASR wells and storage of up to 300,000 acre-feet in the ELP basin, subject to requirements documented in a letter dated July 12, 1994 from Lowell Preston, FCGMA, to Eric Berg [sic], Calleguas (see Attachment B). The requirements included well permitting, water quality analysis and reporting, location of injection and extraction, use of the water within Ventura County, and ongoing review of the effects of injection on surrounding basins. In the ensuing years, Calleguas invested over $180 million to build 18 ASR wells and associated infrastructure to store water in the ELP basin and extract it for local use when imported water supplies are unavailable. In operating the ASR project, Calleguas has fully complied with the requirements for the project set forth by the FCGMA Board. Indeed Calleguas went beyond the FCGMA requirements after operation during a drought between 2007 and 2011 indicated water level drops of between 40 and 100 feet in the ASR wells. At a cost of $53.9 million, Calleguas terminated a contract with Metropolitan that required extraction from the ASR project during multi-year droughts and committed to extract only for Calleguas’ purposes when imported supplies are cut off for emergencies or scheduled maintenance. Calleguas stored and extracted water through the ASR wells from 1993 to the present. As of January 31, 2018, Calleguas had 11,668.38 acre-feet stored in the ELP basin via injection. This stored water was purchased by Calleguas from Metropolitan at a total cost of more than $10 million, representing a valuable asset and investment in regional water supply reliability. Calleguas In-Lieu Groundwater Storage In conjunction with the ASR Project, Calleguas has stored water through in-lieu methods by delivering foreign water to pumpers for use instead of pumping. The FCGMA Board of Directors approved participation in an in-lieu water storage and associated credit and exchange program between Calleguas and each of following pumpers on the dates listed below. Basin Pumper FCGMA Board Approval East Las Posas Ventura Co. Waterworks District #1 October 25, 1995 East Las Posas Berylwood Mutual Water Company May 22, 1996 East Las Posas Zone Mutual Water Company May 22, 1996 West Las Posas Crestview Mutual Water Company September 25, 1996 West Las Posas Ventura Co. Waterworks District #19 October 25, 1995 West Las Posas Solano Verde Mutual Water Company June 28, 2006

The program involved delivering imported water in lieu of pumping. For each acre-foot of imported water delivered, an acre-foot of groundwater credits would be transferred from the pumper to Calleguas. The FCGMA Board required that the extraction rate and location of pumping of credits associated with this storage be subject to approval of the Agency Coordinator or Agency Executive Officer. Calleguas stored water under this program between 1995 and 2016. Calleguas extracted water previously stored in East Las Posas subbasin between 2007 and 2011. Calleguas has not extracted any water stored in the West Las Posas subbasin.

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The table below lists the water quantities Calleguas had in storage pursuant to this in-lieu program as of the end of 2015. All transfers were documented by letters to the FCGMA jointly signed by the pumper and Calleguas.

Subbasin Quantity of Credits (acre-feet) East Las Posas 6,220 West Las Posas 25,192 Total 31,412

This stored water was purchased by Calleguas from Metropolitan at a total cost of more than $20 million, representing a valuable asset and investment in regional water supply reliability. Current Status Today, approximately 660,000 people rely on Calleguas for three-quarters of their water supply. Due to the geographic location of its service area, Calleguas typically receives exclusively SWP water, with the ability to receive no more than 15% of its supplies from the Colorado River. The SWP supply flows through over 500 miles of reservoirs, aqueducts, and pumping facilities to Castaic Lake, then through Metropolitan pipelines and a treatment plant to Calleguas’ connection in Chatsworth. Calleguas delivers the water through a tunnel in the Santa Susana Pass and pipelines in Simi Valley. There is little redundancy in this supply infrastructure and it traverses many seismically active areas. For this reason, Calleguas must be ready for an unplanned outage that could occur at any time and last several months. For an average of one week per year, the ASR Project provides water when routine maintenance and inspection are performed on upstream imported water infrastructure. It also stands by ready to provide water for a longer period when the next emergency occurs, cutting off imported water supply unexpectedly. Together with Lake Bard, the ASR Project is a vital emergency water supply for three-quarters of the population of Ventura County. FCGMA Obligation to Protect Stored Water As water is stored in the ASR Project, water levels in the aquifer stop declining and/or rise. As water is pumped from the ASR project, water levels in the aquifer decline. If, before the ASR project is operated during an outage, water levels have already declined due to non-Calleguas pumping in the basin, Calleguas’ ability to extract water will be limited. When Calleguas invested in the ASR Project, it relied upon the FCGMA’s assertions that it would “protect injected foreign water” because it is “essential to …provide protection from … water supply emergencies” (FCGMA Resolution No. 1993-2). Paramount to such protection is the maintenance of groundwater levels by FCGMA in the East Las Posas Management Area (ELPMA) commensurate with levels adequate to protect Calleguas’ stored water and to allow the ASR facilities to operate to recover that water during outages. As evidenced by chronically declining groundwater levels in the ELPMA and eastern WLPMA (see Attachment D), FCGMA’s past efforts have not adequately protected Calleguas’ stored water. Calleguas believes that FCGMA’s obligation to protect storage activities go beyond FCGMA’s SGMA obligations and, therefore, require near-term measures to protect stored water that are implemented sooner than required to comply with SGMA. For long-term planning and SGMA compliance, the GSP sustainability criteria must be designed to address Calleguas’ right to store and recover water and the FCGMA’s obligation to protect these rights.

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LPVB PDGSP Comments Calleguas understands that FCGMA released the PDGSP to facilitate stakeholder engagement and input into developing a final GSP. Calleguas appreciates FCGMA’s effort to facilitate stakeholder engagement at this juncture in the GSP development process. At the time of release, FCGMA emphasized that the PDGSP is a preliminary draft and that some sections are not complete and the final GSP, that will ultimately be adopted by the Board of Directors, may be significantly revised. Later, comments made during the January 3, 2018 FCGMA Board of Directors meeting indicated that FCGMA considers PDGSP Sections 1 and 2.1 through 2.3 to be substantially complete (despite numerous placeholders on key issues), meaning such sections are to be considered proposed content for a final GSP. At this same meeting, it was also suggested that the remaining sections are to be considered working drafts, subject to considerable change. Despite these distinctions, this comment letter addresses the entire PDGSP because it was formally released for public comment. Calleguas reserves the right to provide comments on future GSP drafts. Calleguas’ comments are organized as follows. Key comments are summarized in the body of this letter. Detailed comments are provided in the enclosed summary table (Attachment C). In some instances the detailed comments provide further explanation of issues raised in the key comments. Key Comments

1. The LPVB PDGSP should be updated to address the commitment to protect injected water that was set forth in FCGMA’s Resolution No. 1993-2, adopted October 27, 1993. Calleguas relied on this commitment when it invested over $200 million to build infrastructure and store water for use during an outage of imported supply. All storage and extraction has been done in accordance with requirements established by the FCGMA Board of Directors in approvals of ASR and in lieu storage programs between 1994 and 2006. It is essential that the LPVB PDGSP include provisions to restore groundwater elevations in the vicinity of Calleguas’ ASR facilities to levels adequate to protect Calleguas’ stored water and to allow the ASR facilities to operate to recover that water during outages. Calleguas has relied up on and continues to rely upon FCGMA to carry out their statutory duty to manage the groundwater basin and protect groundwater levels.

2. The LPVB PDGSP should be updated to comprehensively address Calleguas’ Aquifer Storage and Recovery (ASR) Project and In-Lieu Storage Program and associated water rights. Calleguas’ ASR Project and In-lieu Program are FCGMA-approved projects that Calleguas has made significant investments to develop and are critical elements of the emergency water supply for a majority of Ventura County residents. While Calleguas’ ASR project and In-lieu Storage Program are mentioned in the LPVB PDGSP, the plan does not fully incorporate these programs as existing water resource management programs (Section 1.2.3) nor does it address how Calleguas’ stored water and rights to recover stored water, existing water resource management programs, will limit operational flexibility in the basin and how the GSP has been developed to adapt to those limits (Section 1.2.4; GSP Emergency Regulations § 354.8(d)).

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Importantly, the proposed sustainability goal (Section 3.2), undesirable results (Section 3.3), minimum thresholds (Section 3.4), and measureable objectives (Section 3.5) do not consider, or acknowledge, Calleguas’ storage rights and existing FCGMA approvals as is required pursuant to GSP Emergency Regulations § 354.26(b)(3). As explained in the detailed comments provided in Attachment C, the sustainable management criteria proposed in the LPVB PDGSP are based on misinterpretations of basin conditions and flawed logic and will result in groundwater pumping that lowers water levels in a way that interferes with and prevents Calleguas from accessing its stored water. Continued pumping in both the East and West Las Posas Management Areas by other pumpers can reduce Calleguas’ ability to recover stored water during critical emergencies, which are significant and unreasonable effects. In addition to these issues, the sustainable management criteria proposed in the LPVB PDGSP fail to acknowledge Calleguas’ right to recover stored water and should be revised to incorporate explicit provisions that accommodate localized lowering of groundwater levels during recovery activities.

3. The LPVB PDGSP analysis regarding basin conditions and sustainable management criteria pertaining to chronic lowering of groundwater levels and reduction of groundwater storage are flawed for the eastern WLPMA and most of the ELPMA and the resulting proposed minimum thresholds will not avoid undesirable results. Undesirable results include continued unsustainable pumping that will interfere with Calleguas accessing its stored water when most needed. The LPVB PDGSP should maximize reasonable use of water from the Basin while avoiding any undesirable result, including lowering water levels. As explained in the detailed comments provided in Attachment C and demonstrated in the Attachment D exhibits, PDGSP Chapter 3 fails to fully acknowledge the ongoing chronic lowering of groundwater levels and storage reduction in eastern WLPMA and most of the ELPMA. Without doing so, the analysis cannot and does not result in sustainable management criteria that will prevent undesirable results. In the WLPMA, rising groundwater levels caused by Calleguas’ in-lieu storage activities are misinterpreted as wet period responses and are used to provide the basis for the proposed sustainable management approach of managing to have “groundwater levels generally returning to near pre-drought levels following a drought.” This is an inaccurate characterization and must be corrected. In the ELPMA, the minimum thresholds are based on arbitrary future declines for drought conditions and an invalid assumption that groundwater levels will recover subsequently. In both of these areas, groundwater levels do not respond to wet-dry patterns and are instead experiencing chronic lowering and storage depletion conditions (as is clearly demonstrated in the Attachment D exhibits). Thus, there will be no recovery from declines in these areas as is assumed by the PDGSP, which will lead to undesirable results, including continued over-pumping of water by other pumpers that impacts Calleguas’ ability to pump its stored water. These issues must be addressed.

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If you have any questions about Calleguas’ comments, please contact me at (805) 579-7115 or [email protected]. Sincerely, Susan B. Mulligan General Manager Attachments:

(A) FCGMA Resolution 1993-2 (B) FCGMA Approval Letter for Calleguas ASR Project (C) Detail Comment Table (D) Referenced Exhibits

cc: Department of Water Resources Eugene West, Chair, Fox Canyon Groundwater Management Agency Board of Directors

Attachment A

FCGMA Resolution 1993-2

Attachment B

FCGMA Approval Letter for Calleguas ASR Project

Attachment C

Calleguas’ Detail Comments on Preliminary Draft Las Posas Valley Basin Groundwater Sustainability Plan

Attachment C Calleguas’ Detail Comments on Preliminary Draft Las Posas Valley Basin Groundwater Sustainability Plan

Attachment C – Page 1 of 24

No. Section Page / Table / Figure / Appendix

Comment

1 TOC TOC-I - TOC-vii The TOC does not show section headings higher than third order, making it difficult to locate topics within the GSP document. For, example, surface water features and climate described in sections 1.2.2.1 and 1.2.2.2 would be difficult to find because it is not logical to search for those subjects in the “Administrative Information” section of the document.

2 N/A N/A Sections noted as incomplete: 1.16, 1.2.2.5, 1.2.4, 1.2.6.1, 1.2.8, 1.3.4, and 2.4.7; Chapters 3, 4, and 5. 3 1.2 Figures The figures referenced in this section collectively do not appear to provide the information required pursuant to GSP Emergency Regulations §354.8(a). 4 1.2 Figure 1-1 The FCGMA boundary is truncated to the northeast.

5 1.2.1.2 1-4 For clarity, a description of the FCGMA’s legal authority to regulate the Expansion Area should be provided because it is located beyond the FCGMA’s jurisdictional boundary.

6 1.2.2.1 & 1.2.2.2

Various Pages These sections provide detailed information concerning surface water features and climate, which does not make sense to be included in the Administrative Information section of the plan. This information is better placed in Section 2 titled “Basin Setting” together with other basin setting information.

7 1.2.2.2 1-11 The information presented in this section concerning projected climate is not sufficient to support the analysis of future water budgets and sustainable yield. Consideration should be given to utilizing forthcoming DWR guidance concerning data, tools, and guidance for incorporating climate change into GSPs.

8 1.2.3 1-15 – 1-16

Tables 1-7 & 1-8

Existing Monitoring and Management Programs, Projects, and Strategies:

Pursuant to GSP Emergency Regulations §354.8c, the water resource monitoring programs and management programs that will be integrated into the GSP must be clearly identified in the GSP (last column of Tables 1-7 and 1-8 “GSP Coordination” is blank for all). A clear description of the nature of the integration should be provided for any programs that will be integrated. The FCGMA-approved Calleguas in-lieu groundwater storage programs in the WLPMA and ELPMA as well as the FCGMA-approved aquifer storage and recovery (ASR) project affect groundwater management and vice versa. These programs must be integrated with the GSP, at a minimum, to prevent unintended consequences for Calleguas and the FCGMA. Beyond avoiding unintended consequences, it may be desirable to coordinate with Calleguas to consider the potential use of Calleguas’ ASR and other facilities to help achieve the sustainability goal.

This section and Table 1-8 should clearly state that Calleguas’ ASR Project is an FCGMA-approved project that Calleguas has made significant

investments to develop. The FCGMA approval should be cited (February 23, 1994).

In addition to listing the general FCGMA Groundwater In-Lieu Credit Program in Table 1-8, separate rows should be included to specifically identify Calleguas’ FCGMA approved in-lieu programs for the WLPMA and ELPMA that Calleguas has made significant investments to develop. The FCGMA approvals should also be cited (October 25, 1995; May 22, 1996; September 25, 1996; and June 28, 2006).

9 1.2.4 1-16

Table 1-8

Limitations on Operational Flexibility:

This section does not adequately characterize the limitations on operational flexibility in the basin created by existing water resource management programs, as required pursuant to GSP Emergency Regulations §354.8d. While some important concepts are mentioned, the concepts need to be developed further and quantified to provide adequate understanding of the nature, location, and magnitude of the limitations and how each will impact basin management. Of greatest concern are Calleguas’ FCGMA-approved ASR project and in-lieu storage programs for the WLPMA and ELPMA. The discussion should characterize Calleguas’ storage activities, associated rights, and obligation of the FCGMA to protect those rights and describe the resulting limitations on operational flexibility in the basin.

Suggested edit: “The City of Moorpark and surrounding unincorporated areas in the WLPMA and ELPMA rely on imported water from the State Water Project (SWP) and or Colorado River imported by CMWD through the Ventura County Waterworks District No. 1, Ventura County Waterworks District No. 19, Crestview Mutual Water Company, Solano Verde Mutual Water Company, Zone Mutual Water Company, Berylwood Mutual Water Company, Camrosa Water District, and California-American Water Company.”




Comment

10 1.2.5 1-17

Table 1-8

Existing Conjunctive Use Programs

The Supplemental M&I Program is not a LPVB program. Discussion of this program should be removed from the text and Table 1-8.

11 1.2.6 N/A

General Plan Land Use Categories:

The City of Moorpark General Plan should be discussed.

Inclusion of Urban Water Management Plans as a subsection (1.2.6.2) of “General Plan Land Use Categories” is not logical. Urban Water Management Plans should be moved to a standalone third level section heading.




Comment

12 1.2.6.2 1-22 to 1-24

Urban Water Management Plans - Calleguas Municipal Water District UWMP:

Requested edits (top of Page 1-22): The CMWD does not operate any wastewater treatment facilities but has historically supports supported the use of recycled water through the ownership and operation of recycled water pipelines and pumping facilities. The In addition, CMWD has made a significant investment in the $200 million Calleguas Salinity Management Pipeline (SMP) transfers that conveys salty water away from surface waters in the southwestern Ventura County region to other beneficial uses or the Pacific Ocean (Table 1-8). The In addition, CMWD actively conducts water conservation supports water use efficiency programs. Such programs include rebate/incentive programs, school education programs, social media, and public workshops.

CMWD agrees with the statement that its primary source of imported supply has become less certain over time due to increased water needs for

environmental uses and climate fluctuations. However, as is subsequently noted in this section, efforts are underway - with strong support of over 30 Ventura County cities, agencies, and organizations - to bolster reliability of SWP deliveries through California WaterFix. Irrespective of this effort, imported water reliance within the region is not a potential obstacle to long-term sustainability of groundwater basins. None of Calleguas’ plans to improve reliability involve increased pumping of sustainable yield in groundwater basins within the FCGMA. Calleguas’ emergency supply reliability plan involves conjunctive use of groundwater basins, but in every case, all water pumped during an outage of imported supply will have been stored in advance of the outage under a groundwater storage program approved by the FCGMA. Such stored foreign water is not part of the sustainable yield of the aquifer. Calleguas’ supply diversification plan includes construction of the SMP to preserve the use of aquifers that are becoming increasingly saline; but groundwater desalters only present an obstacle to long-term sustainability if FCGMA grants additional pumping allocations to entities building desalters.

In light of this, we recommend that the following edits:

o Remove (top of Page 1-23) “…the goal of reducing imported water, which is recognized as having lower reliability than local supplies. (Such

recognition is not specified in either the legislative findings or intent of SBX 7-7 and highly dubious given existing regional groundwater conditions and import-dependent recycled water programs.) and add the following sentence as a point of clarification: “Moreover, Calleguas supports a number of local conservation, recycling, and groundwater recovery projects to help offset increasing imported water demands.”

o Remove (middle of Page 1-23): “The CMWD’s reliance on imported water supplies presents a potential obstacle to long-term sustainability in that the main source of supply, the SWP, is becoming increasingly unreliable due to aging infrastructure, increased allocation for environmental purposes, and climate fluctuations.”

o Remove (middle of Page 1-23:”CMWD’s goal of relying less on SWP supplies has the potential to add additional strain on the existing water

supplies, including groundwater.”

Lastly, it should also be noted that Calleguas’ UWMP does not call for less reliance on SWP supplies, and in fact demand for imported water is projected to increase by 5% between 2020 and 2040.Therefore, we recommend that the following sentence be removed: The UWMP assumes a demand increase of 15% through 2040 and replaced with: The UWMP assumes an increase in imported normal year demand increase of 5% between 2020 and 2040.

13 1.2.6.2 Figure 1-8

Comments on Figure 1-8: The basin boundaries do not reflect DWR-approved basin boundary modifications and should be updated. The Calleguas service area boundary is missing in many areas. For example, the western portion of LPVB is and most of Pleasant Valley Basin is

not within Calleguas MWD service area, but appears as such in the map. This is important because these areas do not have access to imported water through Calleguas.

Similar comment for UWCD – cannot tell where the UWCD boundary is in many areas. This map is difficult, at best, to read at this scale and should be zoomed into the LPVB.




Comment

14 1.2.6.2 1-25

VCWD No. 1 UWMP sections titled “How the Plan May Affect…” and “How the GSP May Impact…“: The text included in these sections does not accomplish the intent of the section headings. The VCWD No. 1 UWMP assumes 6,756 AFY of

groundwater pumping from the ELPMA through 2040 (5,000 AFY is from the planned Moorpark Desalter). Pursuant to the GSP Emergency Regulations, discussion is needed concerning how these assumptions are either impacted by the GSP or vice versa.

Same issue for UWMP assumptions concerning increased recycled water use, which will result in reduced groundwater recharge to the ELPMA. Discussion of the West subbasin is not applicable because the VCWD No. 1 service area does not include any land in the West subbasin. Discussion of the Epworth Gravels Aquifer is not applicable because VCWD No. 1 does not pump from this aquifer.

15 1.2.7.1 1-26 – 1-27 Much of section, while good information has nothing to do with well permitting and should be deleted or moved to a more appropriate section.

16 1.2.8 1-28 The PDGSP states: “The Initial Notification was completed with the FCGMA submittal of the Notice of Intent on February 24, 2017, to the DWR to develop a GSP for the LPVB.” How does the FCGMA reconcile the fact that the Initial Notification was submitted approximately two years after starting work on the GSP?

17 1.3.2 1-29 – 1-31

Add a new category should be added under section 1.3.2 to identify storage rights. Storage rights are important interests that may be affected by the use of groundwater in the LPVB. CMWD’s storage rights have been approved and acknowledged by the FCGMA and these interests should be listed. CMWD has made significant investments to secure storage and the GSP should acknowledge these rights and impacts that could occur based on groundwater use by others in the LPVB.

18 1.3.2 1-29 There are no permitted or licensed surface water diversions in the LPVB. The discussion of Camrosa should be deleted because Camrosa does not divert surface water in the LPVB (Conejo Creek is not located in the LPVB).

19 1.3.2 1-30

Based on other sections of the PDGSP, there do not appear to be any demonstrated environmental groundwater uses in the basin. It has not been demonstrated that that riparian vegetation is dependent on groundwater as opposed to surface water, which is largely comprised of wastewater treatment plant and City of Simi Valley dewatering discharges to Arroyo Simi/Las Posas. Therefore, this section should state that no environmental groundwater uses have been demonstrated.

20 1.3.6 1-34

Appendix A

It is noted that the Public Outreach and Engagement Plan mentioned in Section 1.3.6 and included in Appendix A of the PDGSP is dated November 2017 and was released with the PDGSP as opposed to at the initiation of GSP planning activities. How does the FCGMA reconcile the fact that the Public Outreach and Engagement Plan was submitted after years of GSP development was completed and after all of the public meetings listed in Section 1.3.3 were held?

21 1.4 1-35 References: CMWD (2013) and CMWD (2016a): The final versions of these reports should be referenced instead.

22 2.2 Various Pages Hydrogeologic Conceptual Model:

This section does not provide all of the elements required pursuant to GSP Emergency Regulations §354.14(d)

23 2.2.1 Figure 2-2

The following issues with Figure 2-2 should be addressed: The Santa Barbara Formation (Grimes Canyon Aquifer) is missing. The San Pedro outcrop (includes Fox Canyon Aquifer) is missing in eastern 2/3 of the basin along northern edge. Recent Alluvium appears to be absent along Arroyo Simi / Las Posas. The formations depicted in light purple and two shades of brown are not included in the legend. The updated version of the Somis Fault location should be utilized. Discontinuities along quadrangle boundaries should be addressed.

24

2.2.2 2-10

Boundaries:

The Springville and Santa Rosa-Simi Fault zones should be described as groundwater flow barriers.




Comment

25 2.2.5 2-15

Data Gaps:

Fourth bullet: “The volume and effect of leakage between the Upper San Pedro Formation and underlying FCA has not been quantified.” o Despite this being listed as a key data gap, the proposed monitoring wells in Chapter 4 do not appear to be selected so as to address this data

gap. o Leakage can now be estimated with the groundwater flow models developed by UWCD and CMWD. The GSP should be updated with

leakage estimates from the groundwater flow models and confirmed later with new monitoring wells specifically selected to address the data gap.

26 2.2.6 2-16

Figure 2-3 Figure 2-4

Maps and Cross-Sections

This section should be moved above Section 2.2.5 Data Gaps.

The cross-sections should be discussed (text only lists figure numbers for the cross sections) or, alternatively, this section could be deleted and the cross-sections discussed and referred to in Section 2.2.4 (Principal Aquifers and Aquitards). The latter approach is suggested.

Figures 2-3 and 2-4 depict discontinuous zones of low-permeability sediments within Upper San Pedro/Saugus and Fox Canyon Aquifer. The GSP should clarify whether the depicted discontinuous zones of low-permeability sediments are based on actual data or are simply artistic in nature. If the discontinuous zones of low-permeability sediments are artistic in nature, they should be removed from the cross sections or, at a minimum, clearly noted as artistic (i.e. not based on data). In either case, the figure and legend should differentiate between the “Clay Marker Bed” bed and the discontinuous zones of low-permeability sediments because the “Clay Marker Bed” is a distinct and mappable unit at the subbasin scale.

27 2.3.1 2-17 The date range for Calleguas in-lieu deliveries provided near the top of page 2-17 is incorrect. In-lieu deliveries were made to WLPMA from 1995-2008 and ELPMA from 1995-2016.

28 2.3.1.1.1 2-18

WLPMA - Upper San Pedro Formation - Historical Groundwater Elevation Trends:

Concerning the discussion of historical Upper San Pedro Formation groundwater elevation trends in WLPMA, the data suggest there are multiple distinct water-bearing zones within the Upper San Pedro Formation. The GSP should evaluate the connectivity of these zones and vertical flow or identify these aspects and note them as data gaps.

29 2.3.1.1.2 2-20

WLPMA - Fox Canyon Aquifer - Historical Groundwater Elevation Trends:

The date range and average for Calleguas in-lieu deliveries listed in the last paragraph is incorrect. In-lieu deliveries were between 1995 and 2008 and averaged 1,800 AFY.




Comment

30 2.3.1.2.4 2-28

ELPMA - Fox Canyon Aquifer - Historical Groundwater Elevation Trends :

Please add the underlined text to the following sentence: “This well is close to the CMWD ASR project well field, and water level declines measured in well 03N20W36G01S between 2007 and 2010 are the result of groundwater extractions from the ASR well field and increased pumping from VCWD No. 1 wells that had previously participated in the in-lieu program during that time period”.

Calleguas storage between early 1990s and 2007 was approximately 27,000, not 29,000 (see Table 2-12).

Please add the underlined text to the following sentence: “Between 2007 and 2010, groundwater production from the CMWD ASR well field and

increased pumping from VCWD No. 1 wells that had previously participated in the in-lieu program caused water level declines of between…”

31 2.3.2 Various Pages

Estimated Change in Storage:

The analysis in this section does not meet the best available science standard of SGMA and has an unacceptably large range of uncertainty in the annual and cumulative storage change results. For example, the negative annual storage change values that are many times larger than annual pumping are not plausible. Another example, the cumulative storage change results for WLPMA (Figure 2-27) range from negative 188,000 AF to positive 58,000 AF. This is an unacceptably large range and suggests that the GSA is not able to conclude whether the WLPMA is gaining or losing storage. The analysis should be replaced with storage change calculations made using the groundwater models, which are now available.

The statement on page 2-29 “The discussion in this section does not account for CMWD storage“ is invalid. The calculations are based on water

levels changes which reflect the effects of Calleguas storage activities. Therefore, the resulting storage change estimates include Calleguas storage. The statement should be replaced with a different statement that clearly indicates that storage change estimates include water stored by Calleguas.


Groundwater Quality:

The figures referenced in this section have overlapping labels that make it difficult to read values.

Discussions of WLPMA water quality: The source of elevated concentrations in the western portion of the WLPMA should be discussed. For example, is this interpreted to be largely resulting from underflow from the Oxnard Plain?

33 2.3.5 2-40

Subsidence:

Infrastructure damage should be included in the list of problems that may be caused by subsidence provided at the end of the first paragraph of this section. Calleguas owns infrastructure in the basin which could potentially be adversely impacted by subsidence, particularly differential subsidence.




Comment


& Figure 2-38

Groundwater-Dependent Ecosystems:

For context, this section should describe conditions along Arroyo Las Posas prior to the existence of non-native flows. Ideally a historical air photo would be included showing that Arroyo Las Posas was a dry wash with virtually no vegetation in 1970 (air photo is available at the County of Ventura).

The text should be revised to clearly indicate that the potential groundwater dependent ecosystems were established and maintained by non-native discharges from the wastewater plants and Simi Valley dewatering discharges to Arroyo Simi, regardless of whether that water manifests as surface water or shallow aquifer groundwater.

The legend should indicate that the green areas are a potential groundwater dependent ecosystem. The western area of indicated potential

groundwater dependent ecosystem is not supported by the data on figure 2-39, which shows depths to groundwater in well 02N20W17J06 ranging from approximately 55 to 85 feet below ground surface, which is far below the generally accepted rooting depths.

35 2.4 Various Pages

Water Budget:

There are significant issues with the water budget presented in the GSP that must be addressed for it to meet the SGMA best available science requirement and adequately support basin management decisions:

The results are lumped for each management area as whole and, therefore, do not adequately characterize the water availability to the main

pumping zone in each area (i.e. Fox Canyon Aquifer), which will largely control sustainable pumping rates. Numerical modeling should be performed to examine the availability of water to the primary pumping zones.

The water budget analysis for ELPMA was completed without the benefit of numerical groundwater flow modeling of the ELPMA. As a result, the

calculations are not calibrated to groundwater levels. The Calleguas numerical groundwater flow model should be used to refine the ELPMA groundwater budget following completion of the FCGMA Technical Advisory Group (TAG) peer review. As part of this effort, the DBS&A recharge results should be reconciled within the overall calibrated recharge rates of the Calleguas numerical groundwater flow model.

The water budget analysis for WLPMA includes a mixture of terms derived from the UWCD numerical groundwater flow model and DBS&A

distributed parameter recharge model. The DBS&A results have not been reconciled with the UWCD recharge volumes. As a result, the water budget presented in the PDGSP is not calibrated to groundwater levels. The DBS&A recharge results should be reconciled within the overall calibrated recharge rates of the UWCD numerical groundwater flow model following completion of TAG’s review of the model documentation.

The reported 2,288 AFY of underflow from the PV Basin into WLPMA derived from the UWCD model is not supported by the hydrogeologic

conceptual model of the basin and underlying data (Table 2-13).

36 2.4.2

& 2.4.2.3

Pages 2-45 & 2-17

Table 2-6

Sources of Water Supply:

Calleguas imported water supplies should simply refer to Metropolitan Water District of Southern California (MWD), as opposed to State Water Project and MWD. Please change this in the third paragraph of Section 2.4.2 and first sentence of Section 2.4.2.3.

Table 2-6: Camrosa does not pump groundwater from the LPVB.




Comment

37 2.4.2.5 Page 2-47 Figure 2-48 Table 2-12

CMWD ASR Water Supplies:

This section and Figure 2-48 should be retitled CMWD ASR Project and In-Lieu Storage Program.

The Table 2-12 data source should be changed to FCGMA. These are the official volumes provided by FCGMA after a comprehensive records reconciliation effort with CMWD in November 2017.

The sentence “Table 2-12 also shows the cumulative amount of CMWD water in storage in 2015 for their ASR project” should refer to the ASR

project and in-lieu program, not just the ASR project.

38 2.4.2.6

& 2.4.4.11

Page 2-47 Page 2-52 Table 2-7

Table 2-14 Figure 2-50

Recycled Water Supplies and Recharge of MWTP Discharge:

The percolation volumes discussed in Section 2.4.2.6 and presented in Tables 2-7 and 2-14 are incorrect. The reported volumes appear to be the total influent volumes to the treatment plant, not the volumes of water discharged to the percolation ponds.

The full amount of discharge to the percolation ponds should not be used as an inflow term in the water budget because it does not account for

evaporation of water from the ponds and other losses. Other losses includes seepage directly to surface water, transpiration by plants (riparian vegetation is very dense immediately adjacent to the percolation ponds), groundwater discharge to surface water (ponds are located in an area having a gaining stream condition). A fraction of the percolated waste water that seeps or otherwise discharges to surface water did not remain in the basin in years that dry weather flows extended beyond the basin boundary (i.e. mid-1990s through approximately 2012). Evaporative losses should be addressed quantitatively. The “other” losses are difficult to quantify accurately and, therefore, should simply be discussed and caveated appropriately in the water budget discussion and Table 2-14.

Last sentence “Figure 2-50 shows the total amount of recycled water use in relation to the other water sources for the ELPMA” is not accurate. The

figure shows the total amount of wastewater generated and discharged to the ELPMA, not the amount of recycled water use. This should be fixed.

39 2.4.4.1 2-48

Percolation of Precipitation:

Precipitation stations and CIMIS stations used for this GSP are not appropriate. Stations located within or closer to the LPVB are available and should be relied upon instead.

40 2.4.4.3 2-50

Basin Groundwater Subsurface Inflow and Outflow:

The reported 2,288 AFY of underflow from the PV Basin into WLPMA derived from the UWCD model is not supported by the hydrogeologic conceptual model of the basin and underlying data.

Subsurface outflows to the PVB from the ELPMA are higher than can be supported by available data. Consideration should be given to using

updated values currently being developed cooperatively by UWCD and Calleguas.

Underflow from Oxnard Subbasin to WLPMA should be revisited after the UWCD model is recalibrated using updated inflows from ELPMA to PVB and addressing the unsupported underflow from PV Basin to WLPMA and after TAG’s review of the re-calibrated model and UWCD model documentation.




Comment

41 2.4.4.4

& 2.4.4.8

Various Pages

Surface Water Recharge through Streambeds & Riparian Evapotranspiration Losses:

WLPMA

o Riparian Evapotranspiration: It is doubtful that plants in these areas are drawing water from the principal aquifers based on groundwater depths. The plants are likely sustained by perched groundwater, agricultural runoff, and interflow. Based on the foregoing, it is not appropriate to include this term in the groundwater budget without proper caveats.

ELPMA

o Section 2.4.4.4 describes a 1,000 AFY loss of water discharged from the Simi Valley Water Quality Control Plant (SVWQCP) and Simi

Valley dewatering wells. Is this really a loss or is it flow measurement error? If it is truly a loss, the cause of the loss should be described and reconciled with the evapotranspiration adjustment made in Section 2.4.4.8.

o Section 2.4.4.8 discusses an additional 3,017 AFY of losses resulting from riparian evapotranspiration. It is not clear whether the 1,000 AFY loss described in Section 2.4.4.4 is included in the evapotranspiration losses described in Section 2.4.4.8 or whether it is an additional loss. The concern is that 1,000 AFY of loss is potentially being counted twice. This should be clarified.

o The assumption in Section 2.4.4.8 that “all riparian vegetation relies exclusively on groundwater during the dry months” is invalid

because Arroyo Simi/Las Posas flows year-round.

o Last paragraph of Section 2.4.4.8 – this paragraph describes an approach to discounting groundwater evapotranspiration to account for soil moisture from surface water. First, the assumption that 80% of riparian Et is from groundwater is without basis and should be deleted together with the associated conclusions. Second, the approach is unnecessary and results in double-counting a portion of wastewater effluent. The wastewater effluent either percolates or is lost to evapotranspiration. So, if the water budget includes the wastewater effluent, which it does, and the full evapotranspiration rate, the remainder goes to groundwater. That is what is happening. If you discount the evapotranspiration, you are in effect overestimating percolation.

42 2.4.4.6 2-51

Mountain-Front Recharge:

No mountain-front recharge is reported for ELPMA as compared to WLPMA. Given the similarities in the hydrogeology and topography between the WLPMA and ELPMA, it is not plausible that there would be 2,131 AFY of mountain front recharge in the WLPMA but none in the ELPMA. This question was raised during a TAG meeting and the response was that ELPMA mountain front recharge is included in the “External Precipitation Percolation” term. However, this does not seem plausible because this term is included in the water budget for both areas and is only a few hundred AFY, compared with several thousand for mountain front recharge. This should be resolved.

43 2.4.5

Page 2-53 Table 2-13 Table 2-14

Current (2015) LPVB Conditions:

The “imbalance” numbers in the third paragraph do not match the values in Tables 2-13 and 2-14.

The first sentence of the last paragraph should include the underlined text: “Some of the ELPMA decrease corresponds to an increase in M&I pumping related to the extraction of stored ASR project water and increased pumping from VCWD No. 1 wells that had previously participated in the in-lieu program”




Comment

44 2.4.5.2 2-54 – 2-56

Estimates of Sustainable Yield (General Comments): FCGMA staff has stated in public meetings that the sustainable yield results presented in the Preliminary Draft GSP are “historical sustainable

yield” estimates and are not intended to be the sustainable yield that will ultimately be used for management. However, the sustainable yield estimates included in the Preliminary Draft GSP are not presented in this context. Rather, the sustainable yield estimates are presented simply as “sustainable yield estimates”. This should be clarified.

As is discussed in more detail in following comments, the sustainable yield estimates presented in this section are seriously flawed and do not meet the best available science requirement of SGMA. The existing estimates should be replaced with new estimates based on numerical groundwater flow modeling analysis of future conditions after TAG peer review of the models has been completed.

First paragraph, last sentence: “If a basin meets its measurable objectives, then by definition the basin pumping is within the sustainable yield”

is not accurate. The basin pumping is within the sustainable yield if there are no undesirable results; thus, the sentence should refer to minimum thresholds.

45 2.4.5.2 2-54

Estimates of Sustainable Yield – WLPMA:

The last sentence of the second paragraph describes using estimates of inflow to the WLPMA as the sustainable yield. This approach is not valid for several reasons:

o Simply looking at inflows does not necessarily address undesirable results, as is recognized in the first paragraph of this section.

o The estimate includes 2,288 AFY of underflow from the PV Basin into WLPMA that is not supported by the hydrogeologic conceptual model of the basin and underlying data.

o The approach fails to recognize that pumping is not the only outflow from the WLPMA. Groundwater underflow exiting the management

area is a loss that should be debited from inflows.

o The approach does not address groundwater storage changes.

o Not all of the inflows are available to the main groundwater production zones. For example, applied water at the surface is not likely accessible to wells in the Fox Canyon Aquifer in a timeframe meaningful to groundwater management.

o The approach is backward looking and does not consider future conditions, such as reduced diversions at the Freeman Diversion.




Comment

46 2-54 – 2-56

Estimates of Sustainable Yield – ELPMA:

The third paragraph describes using estimates of inflow to the ELPMA as the sustainable yield. This approach is not valid for several key reasons:

o ASR injection should not be included in the sustainable yield estimate. Injected water is stored foreign water designated for subsequent extraction by Calleguas and is not placed in the basin for other uses.

o Simply looking at inflows does not necessarily address undesirable results, as is recognized in the first paragraph of this section.

o The approach fails to recognize that pumping is not the only outflow from the ELPMA. Riparian ET as well as groundwater underflow and base flow exiting to the Pleasant Valley Basin are losses that should be debited from inflows.

o The approach does not address groundwater storage changes.

o Unlike the WLPMA, the author makes an attempt to address availability of inflows to the main groundwater production zones. 25% of

the certain inflows are assumed to be available to the Fox Canyon and Grimes Canyon Aquifers. While the author believes this is a “reasonable estimate,” no justification is provided and thus it appears to be arbitrary and unsupported.

o The approach is backward looking and does not consider future conditions, such as reduced inflow from Simi Valley and Moorpark

WWTPs.

The remainder of the section deals with uncertainty of the sustainable yield estimate. Many uncertainty assumptions are lacking justification and thus appear to be arbitrary. Uncertainty should be defined using sensitivity analysis results from the numerical models.

47 2-46 2-56 – 2-58

Uncertainties in the Water Budget

This section should be revised following recalibration and incorporation of the UWCD numerical model for WLPMA and incorporation of the Calleguas numerical model for ELPMA and Epworth MA (following completion of TAG’s review of the both models).

This section should clearly identify which uncertainties apply to which management areas (some apply to just one).

Uncertainty No. 1 – This bullet item should be revised. First, this uncertainty is relative to the primary pumping zone (i.e. Fox Canyon Aquifer) not the groundwater system in general. Return flows may be available to the “groundwater system” but only portions that do not supply water to many wells. Second, the timeframe is not the only consideration. Quantity is important too – some return flows may never reach the primary pumping zones.

Uncertainty No. 7 – Please see prior comments about problems with how evapotranspiration was calculated.

Uncertainty No. 11 – This discussion conflicts with Table 2-13, which says underflow is derived from the UWCD model.




Comment

48 3 N/A

Sustainable Management Criteria:

Global Comments:

Overall, Chapter 3 does not meet the requirements of SGMA and the GSP Emergency Regulations. The FCGMA has not gone through the SGMA-required process to define significant and unreasonable effects. These are policy decisions which have had almost no discussion by the FCGMA Board and very limited input from stakeholders to date. Despite this fact, the GSP proposes minimum thresholds that are based on an incomplete, at best, evaluation of significant and unreasonable effects.

Page 3-1: The statement “Year over year groundwater levels may decline during a drought, but sustainable management results in groundwater

levels generally returning to near pre-drought levels following a drought, and the avoidance of undesirable results” is not valid for the eastern WLPMA and the entire ELPMA. Groundwater levels in these areas do not exhibit a wet-dry - rise-fall pattern and are instead experiencing chronic lowering conditions in many areas. Therefore, repeated references throughout Chapter 3 to springtime high groundwater levels, drought responses, and the concept that sustainable management results in groundwater levels generally returning to near pre-drought levels following a drought is erroneous for eastern WLPMA and the entire ELPMA. The text should clearly state that the logic presented refers only to the western and central WLPMA and the Epworth MA only. A different approach should be presented for evaluating eastern WLPMA and ELPMA, which are experiencing chronic lowering of groundwater levels.

49 3.1 3-1

Introduction to Sustainable Management Criteria:

Exclusive reliance on FCGMA Planning Goals is not appropriate for the reasons listed below. Although the FCGMA Board could choose to consider these previously-adopted goals when it decides what significant and unreasonable effects are, it has not done so to date.

o Development of the planning goals was completed without considering potential effects on the beneficial uses and users of groundwater, land uses and property interests, and other potential effects, as required pursuant to the GSP Emergency Regulations. Specifically, Calleguas’ storage rights were not considered in the development of the planning goals.

o The planning goals were developed prior to the GSP Emergency Regulations.

o It is also noted that planning goals were developed two years prior to the initial notification submittal to DWR and issuance of the Public Outreach and Engagement Plan.




Comment

50 3.2 3-1

Sustainability Goal:

This section proposes the following sustainability goal: “…maintain Las Posas Valley Basin (LPVB) groundwater conditions at 2015 levels, but to allow enough operational flexibility that groundwater levels could still decline without undesirable results and then return to at least 2015 levels.” This proposed sustainability goal is seriously flawed for the following reasons:

o The goal of sustaining 2015 groundwater levels with allowance for declines is provided without any justification and is, therefore, arbitrary. The proposed goal was not developed in the context of defining and preventing significant and unreasonable effects, with consideration of potential effects on the beneficial uses and users of groundwater, on land uses and property interests, and other potential effects, as required by the GSP Emergency Regulations. Specifically the proposed goal does not address Calleguas’ storage rights, which continue to be impacted by ongoing chronic declines. Additionally, the sustainability goal should include a provision for recovery of stored water by Calleguas.

o For the ELPMA and eastern WLPMA, the goal is inconsistent with a condition of ongoing chronic lowering of groundwater levels and storage depletion. It is unclear what would cause the assumed groundwater level recovery because these areas do not respond to wet-dry patterns and are instead experiencing chronic lowering conditions. This is evidenced by the numerous hydrographs provided in Appendix B of the PDGSP that depict chronic lowering of groundwater levels even during wet periods. A few example hydrographs are provided in Attachment C, which are briefly described below: Eastern WLPMA – PDGSP Appendix B - 02N20W06R01S hydrograph shows chronic lowering of groundwater levels since at least the

1980s interrupted by in-lieu delivery-induced recovery from mid-1990s to late 2000s (Attachment C – Page 1). Without in-lieu deliveries, groundwater levels would have continued to decline precipitously, as they have since termination of the in-lieu deliveries.

Southwestern ELPMA – PDGSP Appendix B - 02N20W10D02S hydrograph shows chronic lowering of groundwater levels since late 1990s (Attachment C – Page 2). The chronic lowering of groundwater levels since the late 1990s is related to decreasing inflows to the basin from Simi Valley and increased recycling by Ventura County Waterworks District No. 1.

Northeastern ELPMA – PDGSP Appendix B - 03N19W19J01S hydrograph shows chronic lowering of groundwater levels since at least

the late 1970s (Attachment C – Page 3). It is noted that the rate of decline decreased in the late 1990s -2000s, coincident with Calleguas’ storage activities.

Central ELPMA (Fox Canyon Aquifer) – PDGSP Appendix B - 03N20W36G01S hydrograph shows chronic lowering of groundwater

levels since at least the late 1950s interrupted by Calleguas storage activities in the 1990s and 2000s (Attachment C – Page 4).

Central ELPMA (Upper San Pedro Formation) – PDGSP Appendix B - 03N20W35R04S hydrograph shows chronic lowering of groundwater levels since at least the late 1990s (Attachment C – Page 5).

The sustainability goal does not address all relevant sustainability indicators (i.e. all except seawater intrusion).

This section does not appear to meet the requirements of the GSP Emergency Regulations § 354.24.




Comment

51 3.3 Entire Section

Undesirable Results:

This section does not address the requirements for defining undesirable results (GSP Emergency Regulations (§ 354.26)). Of greatest concern is the fact that the requirements of § 354.26(b)(3) has not been met. § 354.26(b)(3) requires the GSA to describe the “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.” Calleguas’ storage rights and FCGMA-approved programs have not been considered in the definition of undesirable results.

References to “key wells”: What are key wells? This is not a term used in SGMA.




Comment

52 3.3.1 3-2 – 3-3

Chronic Lowering of Groundwater Levels:

1st paragraph: o “Mitigate or minimize undesirable results” is not what SGMA requires. SGMA requires management to avoid undesirable results.

o Discussion of impacts caused by groundwater levels dropping below well screen: Undesirable results would occur before groundwater levels

drop below well screens. Calleguas’ ability to recover stored water in ELPMA during an emergency would be impaired even with groundwater levels above the well screens in Calleguas’ wells if groundwater level declines are the result of activities unrelated to Calleguas ASR recovery pumping. Similarly, Calleguas’ ability to recover its WLPMA storage is significantly and unreasonably impacted by allowing groundwater levels to continue to decline. For non-Calleguas wells, a significant and unreasonable production loss could occur with levels above well screens.

2nd paragraph: Decreased discharge from the SVWQCP is cited as the primary reason chronic lowering of Shallow Aquifer groundwater levels could

occur. The text should also state that increased pumping from the Shallow Aquifer could also cause chronic lowering of Shallow Aquifer groundwater levels. It should also be noted that declining Shallow Aquifer groundwater levels would impact the water balance of deeper aquifers.

3rd paragraph: It appears that undesirable results (and later minimum thresholds) are being defined on the basis of anticipated water level declines

during a drought from a 2015 groundwater elevation starting point. The logic follows that if recovery occurs following the drought, the management area is sustainably managed. This approach is seriously flawed and does not meet the requirements of the GSP Emergency Regulations:

o As explained in Comment No. 50, the ELPMA and eastern WLPMA do not respond to wet-dry patterns, as evidenced by numerous

hydrographs that depict chronic lowering of groundwater levels even during wet periods (please see Attachment D for representative annotated hydrographs).

o The approach is inconsistent with the SGMA requirement to identify significant and unreasonable effects and define minimum thresholds to prevent them from occurring. Rather, the GSP appears to assume that significant and unreasonable effects would not occur at groundwater levels experienced during the proposed allowance for declining groundwater levels (even though the approach would allow groundwater levels to decline below historical lows in many cases). In fact, the author later acknowledges that the GSP regulations are not being followed in the minimum thresholds discussion: “At what point a chronic lowering of groundwater levels in the ELPMA would impact beneficial groundwater uses is not clear.” (Section 3.4.1.3 page 3-12). Calleguas disagrees with this conclusion. It is more accurate to say that the potential impacts have not been evaluated. Impacts to beneficial uses are the principal potential undesirable results that must be evaluated technically and with stakeholder input. Calleguas’ storage rights and ability to recover stored foreign water during an outage of imported supplies are key considerations in the required evaluation.

o The proposed approach for evaluating undesirable results (and, later, defining minimum thresholds) does not take into consideration the need

to preserve Calleguas’ ability to recover stored water during an emergency. As proposed, the GSP will enable continued pumping that impacts Calleguas’ ability to recover its stored water to the detriment of Calleguas’ ratepayers. This is an unacceptable outcome from Calleguas’ perspective. This is inconsistent with guarantees made by FCGMA upon which Calleguas relied on when investing over $200 million dollars to protect water supply in its service area.




Comment

53 3.3.1.1 3-3

Chronic Lowering of Groundwater Levels - WLPMA:

Second Paragraph: The statement “In general, the majority of the wells in the eastern part of the WLPMA show sharp groundwater level declines during drought periods with some increase during higher than average precipitation and recharge (Section 2.3.1).” is not accurate because it incorrectly interprets rising groundwater levels in the eastern WLPMA during the mid-1990s through 2008 as a solely a wet period response and fails to account for Calleguas in-lieu deliveries during this period. It is likely that water levels would have continued declining during this period without the in-lieu deliveries (please see exhibit on Page 1 of Attachment D).

54 3.3.1.3 3-4

Chronic Lowering of Groundwater Levels - ELPMA:

First Paragraph:

o The statement “As in-lieu water deliveries decrease and CMWD produces water from their Aquifer Storage and Recovery (ASR) wells, groundwater elevations in these wells decline more precipitously (see Section 2.3.1)” should be discussed separately from findings suggestive of susceptibility of the ELPMA to chronic lowering of groundwater levels. Characterizing the ASR in this way undermines good water resource management and is not technically or legally correct. Localized groundwater level lowering during times of stored water recovery by Calleguas should be considered an expected and acceptable result in the GSP. It should be separated from any discussion of undesirable results because conjunctive use of stored water is desirable and is important for the overall basin management. The GSP should specifically allow for the recovery of previously stored imported water from the basin without the groundwater level lowering being considered an undesirable result.

o Last sentence: “These findings suggest that the ELPMA could be subject to the undesirable result of a chronic lowering of groundwater levels.” Calleguas disagrees with this conclusion. Calleguas believes the ELPMA is already subject to ongoing chronic lowering of groundwater levels in many areas.

Third Paragraph: The discussion of impacts from increased Shallow Aquifer pumping should also include mention of decreased recharge to deeper

aquifers.

55 3.3.2 Entire Section

Reduction of Groundwater Storage:

This section does not provide a definition of undesirable results as required by the GSP Emergency Regulations.

This section does not address Calleguas’ groundwater storage. Calleguas’ groundwater storage should be addressed explicitly in this section. This section should recognize the Calleguas’ investment of more than $200 million in the ASR and in-lieu programs which were approved by FCGMA. Loss of stored water other than that which occurs via Calleguas’ recovery activities should be characterized as an undesirable result. The water stored by Calleguas pursuant to its agreements with FCGMA and the right of Calleguas to recover that stored water should be specifically recognized in the GSP. It should also be recognized that Calleguas’ recovery of its stored water should not be considered to cause undesirable results even if groundwater storage is reduced as a result.

All comments on Section 3.3.1 also apply to section 3.3.2.




Comment

56 3.3.2.1 3-5

Reduction of Groundwater Storage - West Las Posas Management Area:

o Last sentence: “This suggests that continued reduction in groundwater storage is a risk for the WLPMA. “Calleguas disagrees with this conclusion. Calleguas believes that the eastern WLPMA is already subject to ongoing reduction of groundwater storage.

o This section should describe impacts resulting from the reduction in groundwater storage in eastern WLPMA. This description should include impacts to Calleguas’ ability to recover in-lieu storage in this area.

57 3.3.2.3 3-6

Reduction of Groundwater Storage - East Las Posas Management Area:

o Second paragraph, first sentence: “The potential exists for the reduction of groundwater storage in the LPVB, which could affect beneficial uses and users.” Calleguas disagrees with this conclusion. Calleguas believes the ELPMA is already subject to ongoing reduction of groundwater storage in many areas.

o Second paragraph, second sentence: Those affected would include agricultural, municipal, and industrial users of groundwater in the LPVB (Section 1.3.2).” Impacts to Calleguas’ ability to recover its stored water should be included in the list of potential impacts.

58 3.3.4 3-7 – 3-8

Degraded Water Quality:

Underflow from the Oxnard Subbasin should be included the discussion of inflows that do not meet Water Quality Objectives.

Undesirable results (and, later, minimum thresholds and measurable objectives) have not been developed for inorganic water quality on the basis that the existing water quality impacts and sources are not related to groundwater pumping. This logic does not appear to be valid. For example, the GSP regulations require that GSAs address contaminant plumes, which are not caused by groundwater pumping. Undesirable results (and later minimum thresholds and measurable objectives) for water quality should be established based on stakeholder input concerning beneficial uses and an understanding of the costs to achieve varying levels of water quality. If, based on stakeholder input, the GSA determines that the ongoing water quality trends are causing or may cause to significant and unreasonable effects, management measures such as blending or well head treatment could be considered to address any significant and unreasonable effects. A regional desalination project supported by replenishment fees could also be considered if it provides direct and immediate benefits to the affected groundwater pumpers in the basin and does not unreasonably lower groundwater levels or impact Calleguas’ ability to recover its stored water.

Section 3.3.4.1 – discussion of nitrate in the Oxnard Subbasin Forebay area is not applicable to the LPVB GSP and should be deleted.

59 3.3.5 3-8

Land Subsidence:

Potential infrastructure damage should be discussed as an undesirable result that could be caused by subsidence. Calleguas and others own infrastructure in the basin that could potentially be adversely impacted by subsidence, particularly differential subsidence across faults. Undesirable results and minimum thresholds for land subsidence should be included in the GSP to protect infrastructure.




Comment

60 3.3.6 3-9 – 3-10

Depletions of Interconnected Surface Water:

This section does not adequately frame depletion of interconnected surface water. It does not describe the groundwater-surface water connection (i.e. Arroyo Simi/Las Posas is a net losing stream across ELPMA with a gaining reach in the middle). Rising groundwater would not exist without non-native flows recharging shallow aquifer in upstream part of basin and added Moorpark Water Treatment Plant percolation in the gaining reach. Given this, depletion of interconnected surface water is only a possibility in the gaining reach. However, there is currently little shallow pumping that could deplete surface water in the gaining reach.

This section talks about the potential for reduced wastewater contributions. This is already occurring and should be described accordingly. Simi

Valley WQCP flows have already decreased 11% in recent years without increased recycling due to improved urban water use efficiency practices. MWTP discharges have similarly decreased due to both improved urban water use efficiency practices and increased use of recycled wastewater..

61 3.4 Entire Section

Minimum Thresholds:

The minimum thresholds proposed in Section 3.4 are invalid because they were not developed in the context of clearly explained undesirable results developed pursuant to the requirements set forth in the GSP Emergency Regulations, specifically § 354.26(b)(3), which requires the GSA to describe the “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.” Calleguas’ ability to recover its stored foreign water under FCGMA-approved programs were not considered in the definition of undesirable results and, hence, the minimum thresholds.

The GSP does not identify the combinations of minimum threshold exceedances that equate to significant and unreasonable effects (see GSP Emergency Regulations §354.26(b)(2)).

This section proposes “Key Wells.” This terminology is not used in the GSP Emergency Regulations, which instead refers to monitoring sites and representative monitoring sites. Are the “Key Wells” intended to be representative monitoring sites?

The rationale for selecting the “key wells” is not provided; thereby, precluding Calleguas’ ability to evaluate the suitability of the selected wells (see

GSP Emergency Regulations §354.36(c)). It is noted that large areas are not represented by a key well; yet, these areas do not have proposed monitoring wells (comparison of Figures 3-1 and 4-11 through 4-13). How will sustainable management be evaluated in these areas?

62 3.4.1.1 Entire Section

Minimum Thresholds – Chronic Lowering of Groundwater Levels - WLPMA:

o Third Paragraph: The analysis using 02N20W06R01 for establishing the minimum threshold is invalid because it does not account for Calleguas in-lieu storage activities and effects, which masked the chronic lowering of groundwater levels in this part of the basin. Filtering out effects of Calleguas storage activities would show that groundwater levels would have likely been declining in the 90s and early to mid-2000s absent Calleguas storage activities (please see exhibit on Page 1 of Attachment D – annotated hydrograph for well 02N20W06R01). This would suggest chronic lowering has been ongoing for quite some time, but has been masked by Calleguas’ storage activities in eastern WLPMA. Thus, the “recovery” that is calculated, which provides the basis for establishing the minimum threshold, is invalid for the eastern WLPMA. Groundwater storage between 2008 levels and historical low levels in this area is largely the result of Calleguas in-lieu storage activities.

o Text: “lows of about -150 feet msl from about 1990 to 2000” is not correct: The low was lower than -150 (approx. -180) and occurred in 1993-1994.




Comment


Minimum Thresholds – Chronic Lowering of Groundwater Levels – Epworth Gravels Management Area:

Setting the minimum threshold 10 feet below historical lows may not prevent undesirable results. Earlier, the PDGSP discussed how historical low groundwater levels resulted in well owners needing to switch from Epworth to Fox Canyon Aquifer wells. This seems like the clearest indication of undesirable results in the entire GSP. The switch to Fox Canyon wells probably did not happen overnight and probably started before the historical low water level was reached. So, would it make sense to set the threshold below historical lows in this case when it is known undesirable results occurred at levels above this level? An attempt should be made to evaluate more appropriate levels by looking at the timing of Fox Canyon Aquifer wells drilled in this area in the 1980s.


Minimum Thresholds – Chronic Lowering of Groundwater Levels - ELPMA:

The Minimum Thresholds for ELPMA Chronic Lowering of Groundwater Levels are invalid for the following reasons:

o This basis provided for establishing the minimum thresholds is insufficient. The only basis provided for developing the minimum thresholds is “Minimum threshold groundwater elevations for key wells were selected to allow for limited additional groundwater-level declines.” No analysis is described that justifies the “limited additional groundwater level declines” (Tables 3-1 and 3-2) and how the approach would prevent undesirable results. The author goes on to say in the next sentence “At what point would a chronic lowering of groundwater levels in the ELPMA impact beneficial groundwater uses is not clear” It is more accurate to say that the potential impacts have not been evaluated, which is a SGMA requirement. Impacts to beneficial uses are the principal potential undesirable result that must be evaluated technically and with stakeholder input. Calleguas’ ability to recover stored foreign water under FCGMA approved programs is a key consideration in the required evaluation.

o The proposed minimum thresholds would enable declines in groundwater levels that will significantly and unreasonably impact, Calleguas’ ability to recover its stored water to the detriment of Calleguas’ ratepayers. Such removal is inconsistent with FCGMA Resolution No. 93-2 and California law. Calleguas believes this is a significant and unreasonable effect not addressed by the minimum thresholds.

o Near the Calleguas ASR facilities, the approach for evaluating undesirable results (and, later, defining minimum thresholds) appear to be developed based on groundwater levels declines interpreted to be climatically controlled. The declines are not climatically controlled, rather they are responses to ASR pumping and resumed pumping at wells that participated in the in-lieu program. The analysis does not attempt to filter out effects of Calleguas storage activities and it should. Doing so would indicate that groundwater levels would have likely been declining in the 90s and early to mid-2000s absent Calleguas storage activities (see exhibits on pages of 3 and 4 of Attachment D). This would suggest chronic lowering has been ongoing for quite some time and negates the calculated minimum thresholds. The lack of complete recovery after the large Calleguas recovery event in 2008-2011 is evidence of this – it essentially represents the net water level decline that would have occurred absent Calleguas storage activities.

o The proposed minimum thresholds are set at levels where undesirable results were previously reported by some well owners. For example,

some well owners reported loss of production in 2010 when groundwater levels were considerably higher than the proposed minimum threshold for 03N20W35R02.

Calleguas believes that a separate set of emergency criteria should be developed for Calleguas’ emergency recovery pumping.




Comment

65 3.4.2 Entire Section

Minimum Thresholds – Reduction of Groundwater Storage

Because minimum thresholds for chronic lowering of groundwater levels are proposed to serve as a proxy for reduction of groundwater storage, all comments on Section 3.4.1 (and associated subsections) apply to Section 3.4.2.

The proposed minimum thresholds for reduction of groundwater storage do not address Calleguas' groundwater storage. Impacts to Calleguas’

ability to recover its stored water should be considered when developing the minimum thresholds for reduction of groundwater storage.

66 3.4.4 3-13 Minimum Thresholds – Degraded Water Quality:

Thresholds are required pursuant to the GSP Regulations

67 3.4.5 3-13 – 3-14

Minimum Thresholds – Land Subsidence:

Thresholds are required pursuant to the GSP Regulations

Thresholds for land subsidence should be designed to protect infrastructure, including Calleguas’ water delivery infrastructure.

68 3.4.6 3-14

Minimum Thresholds – Depletions of Interconnected Surface Water:

It is not appropriate to include minimum thresholds related to potential GDEs for multiple reasons:

o The potential GDEs have not been determined to be actual GDEs.

o Even if the potential GDEs are determined to be actual GDEs, the FCGMA has not made a finding concerning whether any significant and unreasonable effects would result from impacts to GDEs.

o Pursuant to GSP Emergency Regulations §354.26, minimum thresholds are not required for sustainability indicators for which undesirable

results are not present or are not likely to occur due to groundwater conditions. The potential GDEs were established by and are sustained by non-native surface water inflows from Simi Valley and discharge to percolation ponds at the Moorpark Water Treatment Plant (the same water that filled up and maintains Shallow Aquifer groundwater levels), not native groundwater. Moreover, there is currently little to no shallow pumping that could deplete interconnected surface water and impact the potential GDEs. Thus, there is no basis for establishing minimum thresholds to protect potential GDEs under current conditions. However, the GSP could acknowledge that increased Shallow Aquifer pumping might impact potential GDEs even in the absence of further declines in non-native inflows. If increased Shallow Aquifer pumping is proposed, it may be necessary to update the plan with minimum thresholds for depletion of interconnected surface water and Shallow Aquifer groundwater levels to protect any actual GDEs that could be significantly and unreasonably impacted.

69 3.5

Measureable Objectives

The proposed measureable objectives are based on 2015 groundwater levels, which is arbitrary and is not sufficiently protective of Calleguas’ ability to recover stored water.

The measureable objectives should be revised based on previous comments concerning undesirable results and minimum thresholds.

70 4 Entire Section This section will need to be reevaluated after the sustainable management criteria are fully developed, particularly the data gaps evaluation and proposed improvements to the monitoring network.

71 4 Figure 4-8A Figure 4-8A incorrectly indicates that the groundwater elevations in the Calleguas ASR wells are not monitored.




Comment

72 4.3.1 4-6 – 4-8

Water Level Measurements: Spatial Data Gaps by Aquifer:

The GSP does not describe the criteria used to identify and evaluate data gaps.

o Based on inferences, the criteria for data gaps appears to be limited to spatial coverage and need for aquifer-specific data. There also appears to be considerable emphasis on assessing underflow between basins. While these are valid considerations, the data gaps should be more clearly tied to the data gaps discussed in the hydrogeologic conceptual model. Chief among these is quantification of the leakage rate between the Upper San Pedro Formation and the Fox Canyon Aquifer, which would require more nested or clustered monitoring wells to monitor vertical gradients.

o The location of proposed well PNW-26 (proposed nested well) is not a good choice because the Upper San Pedro Formation is very thin (or

absent) in that area.

o Proposed well locations should be identified in the interior of the ELPMA (and WLPMA) to assess the leakage rate between the Upper San Pedro Formation and the Fox Canyon Aquifer

o The GSP states that all proposed monitoring wells will characterize inter-basin flow. A minimum of three wells is needed to calculate groundwater flow. Yet three wells have not been proposed along the boundaries. It is unclear how these wells will accomplish this goal unless they are combined with other wells screened in single aquifers.

73 4.3.2 4-8

Water Level Measurements: Temporal Data Gap:

Transducers should be considered for addressing the temporal data gaps. Transducers provide significantly more robust data than manual measurements.

74 4.3.3 4-8 – 4-9

Subsidence Monitoring:

Baseline surveys should be performed prior to groundwater levels reaching historical lows. The benchmarks should be selected to provide transects across areas where subsidence would be expected to be greatest, across faults where differential subsidence could occur, and near infrastructure susceptible to potential significant and unreasonable effects.

75 4.3.4 4-9

Shallow Groundwater Monitoring Near Surface Water Bodies and GDEs:

The location of the proposed Shallow Aquifer monitoring well PNW-27 is not a good choice for potential GDE monitoring because the water table is this area is expected to be below the generally accepted rooting depths (see levels for nearby well 02N20W17J06).




Comment

76 4.3.5 4-9 – 4-10

Surface water: Stream Gauges and Measurements of Interconnected Surface and Groundwater:

The GSP describes difficulties in monitoring streamflow in the ELPMA and concludes that a numerical surface water model should be developed to estimate infiltration and streamflow depletion. Calleguas disagrees with the conclusion that a surface water model is needed for the reasons listed below. The GSP should instead recommend additional surface water flow monitoring and revisit the need for a surface water flow model during future GSP updates.

o The logic is circular. How would the surface water model be calibrated in the absence of sufficient flow data? The model error would likely exceed the streamflow depletions that the model would be built to evaluate.

o The inability to measure surface water flows has not been demonstrated. In fact the opposite is true. Calleguas sponsored two flow studies in 2011 and 2012, which have provided the basis for understanding streamflow percolation in the GSP. Drop structures provide convenient locations with favorable characteristics (a physical structure for mounting equipment and simple rating curve geometry) for measuring low flows, which dominate the records. These sites could be used to monitor the areas where groundwater and surface water are interconnected during dry weather.

o In terms of water balance considerations, Arroyo Las Posas is a net losing stream under dry weather in most years now and likely in the future due to decreasing inflows from the non-native water sources. A model or even gaging within ELPMA is not needed to conclude that all of the dry weather flow is evaporated, transpired, or percolated – one simply has to observe that the surface water flow terminates within the basin. Because depletion of wet weather flows is not a concern, wet weather gauging and modeling are not needed to assess high flows.

o Streamflow depletion should not be a concern for the GSP because there is currently very limited pumping from the Shallow Aquifer and the

surface water flow is sustained by non-native flows, whether it is non-native surface water flow or rising groundwater that originated as non-native surface water that percolated further upstream. Groundwater users need not pay for an expensive model to estimate something that is not a concern under current operational conditions. If increased Shallow Aquifer pumping is proposed, the project proponents could pay for the model.

77 4.4.2 4-11

Schedule Requirements for Monitoring Groundwater Quality:

The proposed analyte list should be expanded to include a full general minerals suite so that stiff or piper diagrams can be created to fully characterize the geochemical characteristics of the groundwater and track changes over time.




Comment

78 5 Entire Section

Projects and Management Actions:

The current content of this section is limited to brief overviews of projects evaluated in the joint FCGMA-Calleguas Las Posas Replacement Water Study. Calleguas understands that this section is a placeholder while the FCGMA Operations Committee develops a process for evaluating projects. Given this, detailed comments are not provided at this time. However, Calleguas notes a few items that require edits or further discussion:

o The GSP planning should consider imported water as a potential basin replenishment or supplemental water supply option. While Calleguas is not actively seeking to sell more water, the reality is that most of the groundwater users in the LPVB area annexed to Calleguas and could simply purchase imported water to supplement their groundwater supplies. This could be done by simply letting groundwater users make business decisions about whether to supplement or not. Replenishment could be accomplished by charging a replenishment fee and having Calleguas deliver imported water in-lieu of pumping or by injecting into the ASR in case where users do not have a physical connection to Calleguas.

o Calleguas ASR Project (Page 5-3) – The Calleguas ASR project, as currently operated, is not a groundwater replenishment project. Calleguas is open to discussing how the ASR facilities could be operated to replenish the basin in addition to meeting Calleguas emergency storage objectives, which would be a potential replenishment project that could be considered for the GSP.

o The desalter projects included in the PDGSP do not increase the basin sustainable yield for all users in the basin and are, therefore, not

replenishment projects and should be removed.

o Calleguas is incorrectly listed as the project proponent for the following projects: Imported Water – South of Delta Limited Term Supplies (Page 5-6) Santa Clara Drain Dry Weather Diversion (Page 5-8) Arroyo Las Posas/Arroyo Simi Arundo Removal (Page 5-11).




Comment

79 5 N/A

Replenishment and Water Market – Limitations on Imported Water Use and Indirect Benefits Resulting from Imported Water Use: As FCGMA considers provision of replenishment water as a management action in the GSPs, it should be noted that only a portion of the land within FCGMA’s jurisdictional boundaries is annexed to Calleguas and Metropolitan. The properties in the Calleguas/Metropolitan service areas have paid property taxes back to the formation of Calleguas & Metropolitan. The taxes paid for construction of the imported water transmission facilities extending to the Colorado River and Northern California. Any new property that annexes has to pay all back property taxes in order to qualify to buy water from Metropolitan and Calleguas (currently $8,623/acre plus administrative costs). Imported water may only be used on property that is annexed to Calleguas and Metropolitan. Furthermore, entities that lie within the Calleguas/Metropolitan service areas may purchase water from entities outside the boundaries but may not sell imported water, groundwater, or surface water to entities outside the boundaries (recycled water is an exception).

Metropolitan’s Administrative Code Section 3104 states that “water sold and delivered by the District shall not be used in any manner which …results in the direct or indirect benefit of areas outside the District including use of such water outside the District or use thereof within the District in substitution for other water used outside of the District.”

Calleguas’ Ordinance No. 12 Section 5 states that “The right of any Member Agency to water served by the District’s facilities shall be restricted to the amount required for uses within the District’s boundaries. No potable water conveyed by the District or produced by a Member Agency shall be delivered or sold for any use outside of the District’s boundaries, nor shall water conveyed by the District or produced by a Member Agency be sold or delivered for any use within the District’s boundaries in substitution for water used outside the District.”

If, for example, a city within the annexed area sold groundwater to a farmer in an unannexed area, the city would then have less groundwater for itself and would have to purchase more imported water to make up the difference. The additional imported water that the city purchases would then have benefitted the farmer who never paid for construction of the imported water facilities needed to bring in that imported water. In a water market, entities within the land annexed to Calleguas & Metropolitan could trade groundwater freely back and forth with other entities within the annexed land and could buy groundwater from entities in the unannexed land, but they could not sell water to entities in unannexed land.

Attachment D

Referenced Exhibits

Attachment D Referenced Exhibits

Attachment D – Page 1 of 5

framing for calleguas’ comments - background and history

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