Managers of California’s most overdrawn aquifers were given a monumental task under the state’s landmark Sustainable Groundwater Management Act: Craft viable, detailed plans on a 20-year timeline to bring their beleaguered basins into balance. It was a task that required more than 250 newly formed local groundwater agencies – many of them in the drought-stressed San Joaquin Valley – to set up shop, gather data, hear from the public and collaborate with neighbors on multiple complex plans, often covering just portions of a groundwater basin.

Altogether, they submitted plans for 20 basins for review by the California Department of Water Resources in January 2020. Earlier this year, DWR rendered its verdict: Most of the basin plans were incomplete.

Now groundwater agencies responsible for 12 of those basins are racing to meet a late July deadline to submit revised plans that meet SGMA’s requirements or risk the state stepping in to manage their groundwater basins. Ten of the basins with plans deemed incomplete are in the San Joaquin Valley; the other two are in Santa Barbara and San Luis Obispo counties.

“We’ve made really good progress by showing our work a little better. We’re going to get there – we have to.”
~Jarrett Martin, general manager of Central California Irrigation District

DWR’s reviewers faulted plans for such things as inconsistent data and definitions, a lack of coordination with other plans and insufficient strategies to address land subsidence, which can damage canals and other infrastructure as a result of pumping too much groundwater. But for many of these agencies, particularly those coordinating solutions for portions of the same groundwater basin, a big part of their challenge is simply having plans that speak the same language.

Despite the state’s verdict, some groundwater managers say they believe they’re well on their way to making the changes needed to ultimately win the state’s approval.

“We’ve made really good progress by showing our work a little better,” said Jarrett Martin, general manager of the expansive Central California Irrigation District, which serves water across more than 143,000 acres and to 1,600 predominantly small farms. “We’re going to get there – we have to.”

Daunting Challenge

California became the last state in the West to regulate groundwater when SGMA was signed into law in 2014. The law’s overarching aim is to preserve groundwater as a resource for a range of human and environmental uses in the state’s 515 groundwater basins through a regionally driven approach.

While groundwater use in California is significant even during wet years, reliance spikes during droughts. Devoid of snowmelt, reservoirs drop instead of filling up in the spring, forcing farmers and cities to dip into their groundwater savings accounts and pump water from the ground. During an average hydrological year, groundwater provides about 40 percent of California’s total water needs but during dry years usage can soar to 60 percent.

Under SGMA, California is requiring local agencies to achieve groundwater sustainability by 2040 or 2042, depending on the severity of overdraft. The plans are supposed to prevent further declines in groundwater levels and avoid “undesirable results” like degraded water quality, land subsidence, stream depletion and harmful effects on drinking water wells. If deadlines aren’t met, regulators at the State Water Resources Control Board can intervene by placing a basin on probation or establishing an interim management plan until local efforts make the grade.

Curing groundwater imbalances will be most difficult for agencies in the San Joaquin Valley, where researchers at the Public Policy Institute of California pegged the region’s annual groundwater deficit at about 2 million acre-feet – or enough to fill San Luis Reservoir, a key component of two major state and federal water projects. 

Martin’s Central California Irrigation District is part of the sprawling Delta-Mendota Subbasin, which stretches across 1,170 square miles in Stanislaus, Merced, Madera and Fresno counties, mainly in the western and central portions of the San Joaquin Valley. In total, 23 groundwater sustainability agencies (GSAs) are crafting six groundwater sustainability plans (GSPs) for the Delta-Mendota Subbasin that must be resubmitted to DWR by July 21. Martin is managing 11 of the GSAs and is chair of the Delta-Mendota Subbasin Coordination Committee.

Due to a broad array of users and the varying hydrogeological makeup of the San Joaquin Valley’s aquifers, Martin’s agencies and others are taking a joint approach for the Delta-Mendota Subbasin.

Combing through the voluminous amount of data and differing solutions proposed by each agency and compiling it into clear, concise plans has presented a major coordination challenge in the Delta-Mendota and other so-called multi-plan basins.

Most experts agree that recharging depleted aquifers will require a bevy of solutions, including major reductions in groundwater pumping and retirement of more than half a million acres of farmland in the valley. Groundwater sustainability agencies that filed their plans in 2020 have been working since then to implement them even as they awaited the state’s verdict.

The daunting challenge of solving California’s groundwater imbalance isn’t lost on anyone involved with regulating or implementing the new framework, said Paul Gosselin, DWR’s deputy director of sustainable groundwater management. “The basins, since they adopted their plans, have been aggressively pursuing those projects and management actions to move towards sustainability,” he said. “I think those agencies have been doing an outstanding job.”

The First Wave: Some Bright Spots

There were bright spots embedded in the first round of reviews, including in Ventura County, where a temperate climate allows Southern California farmers to grow strawberries, citrus, avocados and vegetables year-round.

To overcome seawater intrusion and other obstacles, Fox Canyon Groundwater Management Agency took charge as the lead GSA for three basins in the coastal area. Fox Canyon used a similar group of consultants to make sure the neighboring basins’ plans were crafted with the same computer modeling and contained compatible hydrogeologic data. Dozens of public hearings and diverse boards of directors were the hallmarks of the plans compiled for the Oxnard, Las Posas Valley and Pleasant Valley basins that ultimately gained DWR approval. 

“DWR had a lot of positive feedback in its approval of the GSPs and really recognized our very intensive stakeholder engagement,” said Kim Loeb, groundwater manager at Fox Canyon and Ventura County Public Works Agency – Watershed Protection.

Loeb says the Ventura agencies’ process was guided by decades of experience, noting that water managers have been implementing strategies to slow seawater intrusion in the area since the 1940s. To fortify the plans, Loeb said the GSAs strove to consult with environmental groups like The Nature Conservancy to ensure that plants and animals that depend on groundwater-supported wetlands and marshes for their water needs were identified and protected.

“That’s the right approach,” said Sandi Matsumoto, director of the conservancy’s California Water Program. “It makes sense to have a range and not just one type of beneficial user included in the process.” 

Along with the three Ventura GSAs, DWR also approved plans for coastal basins in Santa Cruz and Monterey counties that have traditionally faced seawater intrusion. Rounding out the list of approved basin plans are the North and South Yuba basins north of Sacramento and Indian Wells Valley Basin in northeastern Kern County.

Though the eight basins passed their first SGMA test, DWR gave each of them recommended actions to take before the first five-year update is due in 2025. 

Common Shortfalls

While the mere filing of the plans represented a significant milestone in the implementation of the landmark groundwater legislation, the state graded plans for a dozen of the basins incomplete and gave them 180 days to fix what DWR defines as deficiencies. Common flaws included poor coordination with adjacent groundwater agencies, failure to address negative effects on drinking water supplies, inconsistent data and insufficient strategies to address subsidence.

For example, in a 47-page analysis of the blueprints submitted by users in the Delta-Mendota Subbasin, DWR – which treats the six plans and coordination agreement as one plan for the subbasin – cast the results as uncoordinated and ambiguous. 

“The plan, while purporting to be coordinated, actually presents a very complicated and disparate range of definitions for what constitutes an undesirable result for each category, such that whether or not something is considered an undesirable result depends on where in the subbasin the condition is occurring,” DWR stated in its analysis last January.

Similar criticisms were raised regarding plans for the Kern County Subbasin, the state’s largest at 2,834 square miles. There, a total of 11 GSAs submitted five plans to manage groundwater resources in the high-priority basin that has an estimated annual groundwater overdraft of 324,000 acre-feet, equal to the total storage capacity of Castaic Lake in northwest Los Angeles County. In California, an acre foot can typically meet the annual needs of two to three average households.

“The GSPs do not establish undesirable results that are consistent for the entire subbasin,” DWR said of the plans submitted for the Kern County Subbasin.

While some fixes are more complicated and technical in nature, DWR’s Gosselin said the main challenge for multi-plan basins like Delta-Mendota and Kern, where a variety of groundwater agencies are coordinating solutions for the entire basin, is just doing a better job of making sure their plans are talking apples to apples instead of apples to oranges.

“They’re on the pathway towards sustainability and we’re just looking at how they’ve set where the goal line is,” said Gosselin.

Gosselin said that communication is particularly important in multi-plan basins, as DWR grades the plans collectively for the whole basin and issues one final determination. If one agency puts forward unrealistic minimum groundwater levels or ignores subsidence, it could jeopardize the collective framework and invite state scrutiny for the entire basin.

‘A Really Tough Basin’

Grassland Water District is one example of a sustainability agency that is praised for having done many things well, but whose work was still kicked back by the state because it was part of a larger basin whose plans were deemed incomplete.

Created more than 60 years ago, Grassland Water District delivers water that sustains the largest remaining freshwater marsh in the West. The district’s primary purpose is to secure surface water from the federal Central Valley Project and deliver it to a 240,000-acre wetland complex made up of federal, state and private refuges located south of the Sacramento-San Joaquin River Delta in Merced County. Despite Grassland’s environmental charge, it falls under SGMA’s umbrella as it gets a small percentage of its annual supply from groundwater.

Folded into the Delta-Mendota Subbasin, Grassland’s GSP was included in the batch DWR deemed incomplete.

“DWR is telling the subbasin ‘You didn’t coordinate adequately, you didn’t use the same methods and you didn’t explain enough of your work’,” said Ric Ortega, general manager for Grassland Water District.

The district’s water is used to flood land to support groundwater-dependent ecosystems and create a food source for birds on the Pacific Flyway. Ortega said the district’s water usage clearly benefits wildlife and contributes to aquifer recharge. But in re-working its sustainability plan, Ortega said Grassland is being forced to divert money and other resources away from habitat restoration.

“We know that we’re sustainable and that we have the same groundwater levels dating back to the 1960s,” said Ortega. “Wetlands are not causing subsidence or degrading water quality.”

The Nature Conservancy, which lobbied in support of SGMA’s passage and offers a free groundwater hub of data and tools to help GSAs craft their plans, applauded Grassland for “accounting for nature’s needs” in its plan. Of 30 different GSPs it reviewed, the conservancy gave Grassland the second highest grade, behind only Pleasant Valley in Ventura County. 

“From our perspective they’re one of the best at trying to manage natural resources even though they are in a really tough basin,” said Matsumoto with the conservancy.

Giving Plans A Tune Up

Despite the unflattering reviews from DWR, many people tasked with compiling the sustainability plans remain confident in the expensive strategies that were developed in consultation with groundwater experts and cutting-edge computer modeling. Instead of a complete overhaul, many like Martin with the Central California Irrigation District say the incomplete plans are mostly in need of a tune up. 

In recent months Martin said he’s attended four consultation meetings with DWR on behalf of his 11 sustainability agencies to learn how to correct the deficiencies. He said great progress is being made on the main faults, which included nonuniform data and inconsistent definitions of undesirable results.

“DWR is telling the subbasin ‘You didn’t coordinate adequately, you didn’t use the same methods and you didn’t explain enough of your work.’”
~Ric Ortega, general manager for Grassland Water District

“We are well suited for what SGMA is requiring and we do have a sustainable system and a sustainable aquifer,” said Martin. “Now it’s a matter of working with our neighbors, partners and [wildlife] refuges on programs and projects to more efficiently and effectively use the resource.”

Further south in the San Joaquin Valley in Kern County, where agricultural sales exceeded $7.5 billion in 2020, some local agencies are already implementing core pieces of their sustainability plans.

The Semitropic Water Storage District has assigned all of its users water budgets and is exploring ways to charge them for surpassing their assigned limits. Semitropic General Manager Jason Gianquinto said the actions are necessary considering the district’s service area accounts for approximately half of the Kern County Subbasin’s total annual overdraft.

With a variety of water sources – from the state and federal projects to the Kern River and groundwater – 14 sustainability agencies are now working together to manage the future of the sweeping subbasin. To get planners on the same page ahead of the July refiling deadline, Gianquinto said the sustainability agencies are making sure there is more consistency within the plans when referring to things like beneficial users or undesirable results. Weekly meetings are occurring throughout the region, with water managers focusing on how one plan may affect another.

Complicating matters has been the return of drought to California, and the fact it’s the first time for everyone involved in drafting and implementing these complex groundwater sustainability plans, Gianquinto added. Although agencies have the authority to limit groundwater pumping, many of their sustainability plans have banked on acquiring water in wet years to replenish their aquifers.

“If you’re looking at trying to do [aquifer] recharge or acquire new water supplies, it’s a little tough when you’re in a drought condition like this,” Gianquinto said. “What we’ve been focusing on are water budgets and making sure landowners have the best information so that they can make decisions.”

The basin will also have to overcome some last-minute agency reshuffling. In April four water districts split from the Kern Groundwater Authority GSA and announced they would file their own GSP, the basin’s sixth to address the deficiencies DWR identified. The newly formed GSAs still must submit their plan by the basin’s July 27 deadline.

Meanwhile GSAs in another multi-plan basin struggling with drought have launched pumping limits and fees to address subsidence that is causing the valley floor to sink near important water conveyance infrastructure like the Friant-Kern Canal. Like its neighboring basins, the Tule Subbasin, which covers parts of Tulare County, is classified as critically overdrafted and its plans were also deemed incomplete.

In evaluating Tule’s plans, DWR determined they lacked detail and didn’t adequately explain how their minimum thresholds – or the lowest acceptable groundwater levels – will affect domestic wells and other groundwater users. 

“Among potential concerns that will have been overlooked as a result are effects on drinking water users including domestic wells, a concern raised by several public comments,” DWR reviewers said.

Eric Limas, general manager of the Lower Tule River and Pixley irrigation districts, which is in the Tule Subbasin, said the two agencies are going to incrementally decrease the base amount of water that farmers can use to achieve sustainable groundwater levels by 2040. The two GSAs have also created a fallowing program and ways for farmers to swap or sell water credits within the basin. Along with trying to reduce demand, the GSAs are pinpointing strategies to direct future floodwater into areas best suited for aquifer recharge. 

“We’ve always been aggressive in doing that and SGMA is just going to require us to be that much more aggressive, especially with the extreme weather conditions that we’ve seen over the last several years,” Limas said during a recent Public Policy Institute of California panel.

Keeping Local Control

Both the state and the local agencies planning to resubmit plans in July are heading into uncharted SGMA territory.

If deficiencies are not addressed and DWR deems a basin’s sustainability plan incomplete for the second time, the State Water Board could potentially step in as enforcer. Following a public notice and hearing period, the State Water Board could place the basin on probation to correct specifically identified problems. Probation would involve gathering information and collecting fees and if the deficiencies aren’t cured within a year, the State Water Board could develop an interim management plan for the basin.  

The State Water Board could only adopt an interim plan after another public notice and hearing period. Under an interim plan, it could potentially do things like impose more fees, require stricter monitoring or limit groundwater use. At any time, basins can show the State Water Board that they’ve fixed a deficiency and petition to get out of the state intervention process.

James Nachbaur, director of the State Water Board’s office of research, planning and performance, said SGMA explicitly gives the State Water Board broad discretion and flexibility to intervene and that basins will be handled on a case-by-case basis.

“The goal is for the state to get out of the way as soon as the board thinks things are on a good track,” said Nachbaur.

Semitropic’s Gianquinto said how the State Water Board will react to inadequate plans remains a wildcard, but he’s trying to keep his eyes on the task in front of him.

“I’m not so much focused on what happens if we go to enforcement,” Gianquinto said. “Right now, the focus is on getting a plan that’s acceptable to DWR.”

Other GSA managers predict the State Water Board will prioritize the most glaring issues if called upon, rather than taking a heavy-handed approach to a basin that narrowly missed the mark.

“My guess would be that they will focus on areas that are causing significant subsidence, or where the water table is dropping hundreds of feet or if disadvantaged communities are going dry,” said Martin who is helping craft the Delta-Mendota plans. “I think a lot of the plans are going to get approved so long as you made a substantial try at addressing DWR’s deficiencies.” 

Since the January assessments, DWR’s Gosselin said every basin has asked the state for help or scheduled consultation meetings. Gosselin has told agencies that it’s better to deliver a complete plan that’s a bit late – even though this would trigger state intervention –instead of a timely but unfinished product. The public will be given 60 days to comment once the reworked sustainability plans are submitted, Gosselin said, adding that DWR is aiming to make its final determinations by the end of 2022.

Stabilizing groundwater levels amid California’s highly variable and changing climate remains daunting, as nearly two-thirds of monitoring wells across the state have declined over the last 10 years. California experienced its second driest year on record in 2021 yet more domestic and irrigation wells were drilled last year than in any of the previous five years.

The mandate to restore groundwater imbalances comes as farmers across the state are toiling through another growing season without their usual supply of surface water. A third-straight year of drought, rapidly sinking reservoir levels and water curtailments are only raising the demand for groundwater.

Drought burdens aside, optimism about clearing the looming SGMA hurdle is sprouting in the San Joaquin Valley. The key now, according to Martin of the Central California Irrigation District, is for the groundwater agencies to keep communication lines open and cut through the minutiae that afflicted the first round of plans. “SGMA is complicated enough,” Martin added. “We need to keep it simple.”

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Reach Writer Nick Cahill at ncahill@watereducation.org, and Editor Doug Beeman at dbeeman@watereducation.org.

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