Successful implementation of the Sustainable Groundwater Management Act (SGMA), including its provision to avoid significant and unreasonable depletion of interconnected surface water, is a high priority for the Environmental Defense Fund (EDF). The lack of established mechanisms for addressing depletions of interconnected surface water makes the implementation of this aspect of SGMA especially challenging. Accordingly, EDF offers recommendations to address the requirements of the law related to depletion of interconnected surface water, commonly referred to as “Undesirable Result No. 6” (UR #6). We propose an approach that we believe provides a reasonable balance among the conflicting factors of rigor, cost, uncertainty, and enforceability that weigh on the implementation of this requirement.
Our goal is to offer a pathway to achieve the fundamental and critical objective of UR#6, which aims to prevent significant impacts to water users and ecosystems that depend on streams and rivers that may be depleted by groundwater withdrawals, in a way that is not unreasonably costly or unproductively burdensome on the Groundwater Sustainability Agencies (GSAs), water users, and state agencies who will bear most of the burden of complying with—or ensuring compliance with—SGMA.