Incomplete Determination of the 2020 Groundwater Sustainability Plans Submitted for the San Joaquin Valley – Kern County Subbasin

Department management has reviewed the enclosed Staff Report, which recommends that the deficiencies identified should preclude approval of the Plan. Based on its review of the Staff Report, Department management is satisfied that staff have conducted a thorough evaluation and assessment of the Plan and concurs with, and hereby adopts, staff’s recommendation and all the corrective actions provided. The Department thus deems the Plan incomplete based on the Staff Report and the findings contained herein.

A. The GSPs do not establish undesirable results that are consistent for the entire Subbasin.

• • 1. While the Coordination Agreement presents Subbasin-wide undesirable results, the Subbasin’s fragmented approach towards establishing management criteria that define undesirable conditions in various parts of the Subbasin does not satisfy SGMA’s requirement to use same data and methodologies.

B. The Subbasin’s chronic lowering of groundwater levels sustainable management criteria do not satisfy the requirements of SGMA and the GSP Regulations.

• • 1. The GSPs relied on disparate methods to develop groundwater level minimum thresholds across the numerous GSPs and management areas.
    2. The GSPs do not consistently and sufficiently document the effects of their selected minimum thresholds on beneficial uses and users in the Subbasin, nor explain how the minimum thresholds and measurable objectives that are set below historical lows will impact other applicable sustainability indicators, specifically water quality, land subsidence, and reduction of groundwater storage.

C. The Subbasin’s land subsidence sustainable management criteria do not satisfy the requirements of SGMA and the GSP Regulations.

• • 1. The Plan lacks a Subbasin-wide, coordinated approach to establishing land subsidence sustainable management criteria.
    2. The GSPs and management areas that use their minimum thresholds for the chronic lowering of groundwater levels as proxy criteria for subsidence do not sufficiently demonstrate that groundwater levels (specifically groundwater levels below historical lows) are a reasonable proxy to avoid land subsidence that would substantially interfere with surface land uses.