One of the key criteria that the Department of Water Resources (DWR) must consider when evaluating whether a GSP is likely to achieve the sustainability goal for the basin is “Whether the interests of the beneficial uses and users of groundwater in the basin, and the land uses and property interests potentially affected by the use of groundwater in the basin, have been considered” (23 California Code of Regulations [CCR] § 355.4(b)(4)).
In regard to this and other statutory requirements to consider and address the needs of all beneficial users in GSPs, a group of NGOs, with the support of Water Foundation, collectively reviewed 31 GSPs in 16 critically overdrafted basins and subbasins.
The organizations collectively submitted detailed formal comment letters to each GSA on the public draft GSPs as well as detailed formal comment letters to DWR on the final GSP documents, within the formal public review period.
The reviews were prioritized towards those GSPs that were considered to be of high priority by our organizations due to the presence of: (1) small drinking water systems, (2) groundwater dependent ecosystems (GDEs), and (3) DACs. Prioritization also considered coverage and interest by the respective organizations, with the goal of selecting at least one GSP per critically overdrafted basin.
Although we did not review all 46 submitted GSPs, the findings from our analysis are both valuable to inform GSP implementation and updates in critically overdrafted basins, and to inform the development and review of GSPs currently being drafted for the remaining high- and medium-priority basins. For each of the five key elements, the following sections discuss: (1) the regulatory basis for consideration of beneficial users, (2) a summary of our review findings, (3) a discussion of how the GSPs should have more adequately addressed the key issues, and (4) a selection of “Model GSP Elements” from reviewed GSPs.
It is the goal of this analysis to share our findings in order to help inform and improve the development of GSPs for non-critically overdrafted basins, as well as to inform opportunities for improvement of GSPs for critically overdrafted basins.