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Tule River Sub Basin GSA MOU June 18, 2018



The Tule River Sub Basin GSA MOU group meeting was held at Lower Tule River Irrigation District headquarters in Tipton on June 18, 2018. This is a group representing all the GSAs in the Tule River Sub Basin. Chairman and engineer Richard Schafer called the meeting at 1:00 pm. The room was packed and the first big item was the status of the draft revisions of the Coordination Agreement. After a bit of discussion, it was agreed the attorneys will look over the document and redline it for comparisons. Mr. Schafer said this is possibly the biggest hurdle for the sub basin to jump and I think that sentiment would apply to just about every sub basin in the San Joaquin Valley.

Hydrogeologist Thomas Harder gave his presentation and said he’s getting close to a sustainable yield but will first get the monitoring network refined. He wants to ensure there isn’t any duplication or opposing actions that could cost time or money. He’s working with Dave DeGroot, Four Creeks Engineering to bring this about. He intends to submit the monitoring plan with a model of it in August. He does some massaging from the GSAs once this report has been submitted. Schafer said the Tule River Association has decades of records on water levels in and around the City of Porterville he can provide. Harder reported he’s had a conversation with the Boswell Farms computer modeler. Dan Vink, General Manager of the South Valley Water Association reported he spoke with Jeoff Wyrick from the El Rico GSA about making sure the modeling from one GSA to the next is compatible and not in opposition. While he had their attention; Schafer asked the board to pay Harder for his work and the board agreed to do so.

Developing a GSP

What criteria needs to be adopted and declared the most sustainable? That was the question for the next item. There was a Best Management Practices document prepared by the DWR. Harder lead the board through the six sustainability indicators linked to undesirable results. You’ve heard these before: chronic lowering of groundwater levels. Harder used a real monitoring well as an example. During the 20-years of SGMA implementation a minimum threshold must be established. That may not be the sustainable goal but you can’t go any lower.

Groundwater storage can’t be significantly diminished and even though there is very little danger of seawater intruding in the Tule Sub Basin the GSP must contain a paragraph of why not. Water quality has to be improved and contaminant plumes can’t impair water supplies. Stanford recently released a report claiming it can determine arsenic from satellite data. That occurs in deep aquifers. DeGroot said SGMA isn’t not about preventing contaminants from entering the groundwater from a surface point source. It is designed to prevent pumping from spreading plumes. There is a plume in Porterville of something nasty known as PCE if I understood. There was a leak at an industrial site and it is being dealt with. Schafer asked what the nitrate minimum threshold should be since it is so in the crosshairs of the Irritated Lands Program. That is a power question. DeGroot said the goal is to prevent the contaminant from moving underground. Beneficial use is the standard Harder suggested. Schafer asked how many monitoring wells need to be established based on density. Harder said he believes groundwater flow paths and boundaries with other basins would be a better guide to number and location of monitoring wells. DeGroot said he believes groundwater quality to be less of a challenge than quantity. Vink said this part of the plan is being tracked by the Regional Board’s CV Salts and nitrate monitoring plans. DeGroot said tracking groundwater flows will help identify any problems. Schafer asked if the monitoring wells for elevation should also be used for water quality and Harder said in most cases yes. Schafer said it would be best to use the same wells for SGMA, the Irrigated Lands and CASGEM. There are a good deal of dairies in the area that have all been monitored for quality for decades that could possibly be used as domestic wells on dairies after 2019. Schafer thinks there is a good chance the Irrigated Lands Program will yield enough monitoring wells for both elevation and quality to meet

SGMA requirements. The folks in Sacramento are actually aware of the need for well integration to save the citizens of the Valley from having to punch holes everywhere until the place looks like Swiss cheese. Identifying the wells should be completed by the end of the year. The entire sub basin needs 110 wells. It was also commented the minimum threshold for contaminants should be no lower than the maximum allowable limits.

The next undesirable result would be subsidence. Harder said to be careful with setting the minimum threshold to prevent subsidence. That could be a different groundwater level than other undesirable results. Harder said there is a computer model to show when subsidence can be expected based on pumping. The Friant Water Authority has contacted him in regards to fixing the Friant Kern Canal’s subsidence problems and he’ll be working with Stantec on this matter. Sean Geivet, East Tule GSA asked how accurate a model will be to prevent subsidence. Harder said there is some guessing involved but it is clear enough to submit to DWR. Harder said subsidence isn’t an issue throughout the entire sub basin. Geivet said just make it a part of each GSA’s GSP. It was asked if population growth was included. Harder said there is a urban model management plan included in the model. Dale Brogan, Delano Earlimart ID said subsidence is connected throughout the sub basin. If it wasn’t there wouldn’t be a problem due to the amount of water imported. Brogan is well respected, not that the rest of the speakers aren’t, but there wasn’t any dissent vocalized due to his statement. I took that to mean agreement. Someone asked if Friant is working on getting the canal fixed and the answer is yes. Harder was recommended by many people in the room to Stantec to sub on this matter and he’s signed up to do so.

The last undesirable result was interconnected surface and groundwater problems and neither Harder or Schafer expected any problems. Harder will jot down a paragraph like the one for sea water intrusion the GSAs can use in their GSPs. Selecting minimum thresholds was a whole other ball of fur. But the BMP has some guides. The coordination agreement will contain these thresholds when they are determined. Brogan said he was not comfortable with each GSA deciding what amount of subsidence is undesirable if they could be in opposition with each other. DEID may be the most vulnerable district to FKC conveyance limitations. A gentleman from DWR was present and I didn’t catch his name, but he said this is one of those situations where you pay attorneys and consultants to sit around the table talking this out. It was widely acknowledged the problems in the western portion and eastern portion are different. The Tule Sub Basin is estimated to be 118,000 a/f overdraft. Schafer said he sees no other way to solve this than take land out of production. He said Governor Jerry Brown has been more interested in the Silicon Valley than the San Joaquin Valley and perhaps a vote for “Mr. Cox” could help.

Brogan said the two main things important to him. If subsidence wasn’t impacting the canal he’d be all for a long term solution but it is already impacting the canal catastrophically. And he and Steve Dalke, GM Kern Tulare ID it’s not just Brogan’s district being impacted by the FKC problem but all the districts downstream of the pinch point in other basins. Brogan said it will take every GSAs in the sub basin to work together. Geivet said having subsidence in the coordination agreement will be different than the GSP. He said determine how much overdraft is allowed and how that impacts subsidence. He said there will be a discussion over subsidence and whether or not the minimum threshold for subsidence is in the coordination agreement or the GSP it will be established. Michael Reed, City of Porterville said to let each GSA develop a GSP and throw it at a consultant. Then the coordination can take place. Vink, frankly said that is a recipe for chaos. He said it is unrealistic to let each GSA go its own way and then try to mash it together. Schafer said we know the magic number is 118,000 a/f and each GSA needs to know its share in order to correct overdraft. Brogan said if the canal wasn’t in play it would be OK to take the 20-years SGMA allows but at today’s subsidence rate by 2024 DEID won’t get enough water through the FKC to meet its peak summer needs. Dalke said KTID already hasn’t had enough water coming through the canal. Someone asked if management areas can extend beyond a GSA. If I understood that was very unpopular. I believe that was supposed to be decided when forming the GSA. Then there was the whole discussion of whether the BMP was binding by law and I’d say the vote was no – but DWR would like it to. Brogan made his declarative statement – DEID finds transitional pumping a non-starter due to subsidence, but it isn’t against supporting the sub basin. It’s a life or death issue for his district.

Moving on Harder said the GSP has to address what the undesirable result is, how that is quantified and what the impact is from the undesirable result. Each GSA has a preliminary estimate of its share of overdraft and that will not be circulated until underground flow can be factored in. This meeting dodged a bullet until August when the update is available. The GSP must have a measurable objective. It could be reached soon or later in the 20-year period. Different wells within a GSA could have a different threshold. But those minimum thresholds can be adjusted as real world data comes to light.

Here’s the fun part: GSAs must develop a sustainability goal that is applicable to the entire basin. The BMP states. “. . . the sustainability goal will likely be one of the final components of GSP development.” Schafer suggested drafting a sustainability goal and asked if one of the GSAs would like a draft of this prepared. Geivet wasn’t too keen on that because he felt he needed to consult with his board and Brogan also felt it’s too early to tackle even a draft of a template. Harder said all the hydrogeologists from the sub basin’s GSAs have had a conference call to clear up how to share data. Only Tulare Lake Sub Basin has a model with the Kaweah and Kern Sub Basins are getting closer.

SGMA requires each sub basin establishes one point person to deal with DWR. This group reiterated Mr. Schafer be officially nominated in this role. Victory. Dalke suggested the group review the Title 23 portion of SGMA in California Water Law for the next meeting.


DeGroot reported the Prop One grant is almost ready and the Tulare County “Distressed County” Grant is also almost ready to cash in. Good for them. DeGroot gave the budget and financial reports. The grants will be very helpful but I may have miswrote when I typed almost ready. Grants and glaciers have more in common than the words that begin with the letter “g”. They both move slowly. If I understood correctly Mr. Schafer has deferred payment for some time. With that the meeting adjourned.

DISCLAIMER OF RESPONSIBILITY; t strives to provide his clients with the most complete, up-to-date, and accurate information available. Nevertheless, does not serve as a guarantor of the accuracy or completeness of the information provided, and specifically disclaims any and all responsibility for information that is not accurate, up-to-date, or complete.’s clients therefore rely on the accuracy, completeness and timeliness of information from entirely at their own risk. The opinions expressed in this report are those of the author and do not represent any advertisers or third parties.

ALL RIGHTS RESERVED.  Copyright 2018 by Don A. Wright   No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise, without the prior written permission of DAW.

SGMA The Sustainable Groundwater Management Act of 2014 calls for the formation of Groundwater Sustainability Areas within Basins and Sub-basins to develop Groundwater Sustainability Plans.

TULE RIVER GSA – Alpaugh GSA, Delano-Earlimart ID GSA, Eastern Tule GSA JPA, Lower Tule River ID GSA, Pixley ID GSA, Tri-County Water Authority GSA

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