HIGH PRIORITY RECOMMENDATIONS TO
Napa County Groundwater Sustainability Agency (GSA)
1. There is a need for leadership beyond just regulatory compliance.
We urge the Groundwater Sustainability Agency (GSA) to take a leadership role in assuring water sustainability, quality, and security, and acting in the best interest of current and future Napa County residents and our environment. We challenge the GSA to go beyond mere compliance in order to better serve the needs of our community.
The state provides requirements for performance and process for the GSP, and gives the GSA authority and responsibility in a defined domain, for sub-basin water availability and sustainability. This is but one area of an interconnected set of water functions. The sub-basin is not independent of hillside surface and subsurface flows that replenish the sub-basin. It is not independent of the sustainability of watersheds. We expect the GSA to forcefully address these interconnections, even though they are not absolutely required by law and the GSA cannot directly cause changes in regulations. We would like to see the GSA working in the interest of Napa County and not just discharging its responsibility to be compliant.
Given the county’s significant reliance on water provided by the State Water Project, that source needs to be included in sustainability estimates, along with uncertainties associated with that source. Our allocation this year from the State Water Project has already been cut to 5% of previous years. We have to consider that this source may be our least reliable water source in future years.
Our communities and wildlife are dependent upon a sustainable water supply. The GSP should detail the impact of water sustainability and uncertainty on each community, with the understanding that natural flora and fauna are communities worth protecting as much as economic interests.
2. Elevate Transparency and Communication of Information and Methodology
The GSP is supported by computational modeling which results in forecasts of future water and confidence levels of water supply, based on climate projections and water withdrawals. We would like to see greater transparency in how models are developed, including assumptions and compromises in modeling made to accommodate the limitations of modeling tools. Our concern is that the modeling tools were developed before the expected extremes due to climate change were recognized and may not be able to adequately address uncertain future scenarios and interactions that can’t be developed from past experience. We are also aware that as we move from fairly predictable cycles to high uncertainty, our modeling may carry assumptions about variables and interactions that could be surprisingly wrong.[1]
In reviewing potential scenarios that will affect water supply and sustainability, the projections should include factors beyond just those that were useful in the era of relative stability. They should consider weather patterns and the interactions between various other systems that can rebound back to water supply. As the pandemic has shown us, interactions between improbable events and human behavior can result in cascades of failures in systems. Current discussion and research should include the nexus between climate and energy, and climate change and water, food, energy, biodiversity, and social equity. The GSP needs to be fully informed by this process, and the plan should reflect the set of interacting forces that have greatest impact on Napa.[2]
3. Define sustainability as long term resource security
The term ‘sustainability’ is used with respect to resources and land usage. Sustainability is often defined as a condition in which replenishment of a resource is equal to the extraction. It is also defined behaviorally as “If we keep doing things as we are, will we damage resources?”
Sustainability is sometimes defined as the absence of undesirable results, but that definition allows encroachment into resources right up to the point of doing damage. It is not preventive, but a fire alarm. When we detect the damage, we often have passed points of no return.
When required to list undesirable conditions, the most often used preventive indicator is the loss of stability in replenishment/extraction balance. Even more preventive an indicator is when there is a forecast of reduced supply relative to consumption. Sustainability is not the absence of adverse conditions; it is balance and stability.
We suggest you use statistical indicators that forewarn of the increased likelihood of adverse conditions, and not the actual occurrence of adverse events.
4. Regulate, monitor and enforce surface water use to ensure sustainable groundwater supply. Assure sufficient clean and continuous flow of rivers and streams to support aquatic and riparian wildlife and natural vegetation.
Groundwater and surface water (streams, creeks and rivers) are inextricably linked, with surface water re-supplying groundwater levels and groundwater helping to hold surface waters at more stable flows. Our natural environments are dependent upon the health of riparian and aquatic ecosystems, which in turn are dependent upon the supply of waters through their channels.
Although the GSP is statutorily focused on groundwater, the overwhelming importance of surface water to our natural habitats cannot be ignored. Water diversions from our river, creeks, and streams pose a definite danger to the maintenance of the health and diversity of the plants and animals. Any diversions of surface water should occur only when the environment has been studied and a determination made that the aquatic and riparian habitat would not be adversely affected. Those diversions that are given a County permit should be routinely monitored to ensure that no more surface water is diverted than allowed. Unpermitted diversions should be brought into compliance.
5. Post-fire testing and monitoring is key to water quality. Include impact on the water quality of increasing wildfires.
Testing in locations where woodlands and structures were burned should be policy. This would be critical to preventing fire-related toxins from entering our groundwater and aquifers. High quality data are needed for all sources and usages.
Wildfires followed by severe winter storms can cause serious erosion, washing topsoil, ash, and possible toxins into riparian areas and into the municipal water supply. This soil, ash sediment, and possible toxins from structures could harm the biological health of the water itself as well as the surrounding environment. In addition, increasing levels of total organic carbon may harm water quality when the carbon reacts with disinfectants used in water purification..
6. Gather, share and communicate high quality data on all sources and usages, including wells.
The GSP should require reporting on all Napa County wells, beginning with the largest consumers. This information should include well location, depth, level, water pumped monthly, date permitted, and method of monitoring. Remote monitoring is a best practice, as demonstrated in Fox Canyon.[3]
Mandatory well metering is considered a drastic action per the most recent GSPAC discussions. But, given that it will take time to implement and develop a monitoring system, we believe it important to begin immediately. We are already in the first stages of a water emergency. Well monitoring will provide greater insights into the condition of aquifers and the relationship between water extraction and the levels of nearby wells.
The GSP should also require reporting on surface water diversion. All water extraction should be measured in order to have a complete picture of water input and usage to form accurate water budgets.
7. Develop and consider scenarios beyond precipitation forecasts
Formal scenario planning will shine a light on the situations we consider unlikely, but that could have a potentially major impact on some or all of the communities in our county. An event that has low probability in a short time frame, such as a major earthquake, aggregates to high probability over longer time frames. When the consequences of such an event are catastrophic, planning must prepare for it.
The scenario planning we expect is for various events and trends that might impact water supply to be described, and interactions between them understood. This should be a formal and facilitated discussion, led by experts in scenario planning, that will develop what is referred to as “inevitable surprises.” These potential major events lie outside of trend extrapolations that are based on modeling. In such exercises, scenarios should be developed that include loss of water from the State Water Project, multi-year droughts, salt water incursion into the delta, earthquakes, fires, energy supply failures, and significant economic events. The water sector does not exist in isolation of other systems that have their own uncertainties.
8. Place a moratorium on commercial development impacting water resources until more robust forecasts are completed
If we keep doing what we are doing, will the future resource be available? The addition of water-consuming commercial developments is hastening the depletion of our water resources. Each development puts us closer to conditions of failure. Development that draws from shared water resources, whether ground, surface, or imported, risks moving us closer to critical conditions.
A moratorium on development that relies on groundwater use should be put in place until a GSP is adopted that provides an accurate reporting of groundwater extraction and surface water withdrawal. Allowing additional groundwater extraction during the development period would undermine the basic assumptions of the Plan.
Likewise, clearcutting of oak woodlands irreparably harms the watershed, reducing the capacity of the watershed to replenish water tables. In addition to the climate impact, clearing oak woodlands should be proscribed. There are ample grasslands for vineyard expansion without removing ecosystems that are linked to the recharge of water tables.
9. Aggregate Regulation and Authorities
While we realize there are inherent political challenges within this area, one of the most expedient actions that should be taken is that the GSA members, in their capacities as members of the Board of Supervisors, review and accept recommendations of the 11/2020 LAFCO report (https://www.napa.lafco.ca.gov/uploads/documents/CountywideWaterWastewaterMSR_ApprovedFinal_11-2-20.pdf).
Specifically, consolidate the various water districts in the county into a single water district. This county-wide water district should be headed by an empowered leadership that can enable the various jurisdictions and water sources to be treated in a unified manner.