From the Desk of Julie Tacker PO Box 6070 Los Osos, CA 93412

Transcription

From the Desk of Julie Tacker
PO Box 6070
Los Osos, CA 93412
805-528-3569
October 4, 2013
Los Osos Community Services District
2122 9th St.
Los Osos, CA 93402
RE: Los Osos Basin Plan Public Review Draft Comments
Dear Los Osos Community Services District Board of Directors,
Please consider the following comments with regard to the Los Osos Basin Plan. I object
to the process in which the public has had limited opportunity to participate in the ISJ to date.
To have its culmination end in $67 million of experimental projects and only 60 days for public
comment is disingenuous and nontransparent. To be compelled to comment in this rushed
fashion, with no expectations for response or influencing change, is also misleading to the
public.
Previous iterations of ISJ memoranda and pre-draft plans have been released over time,
none of which included cost projections associated with the recommendations. Over the same
timeframe, the public has been grappling with the high costs of the wastewater project. Had
these costs for basin management been known, there would have been little to no support for
water management programs that still may encounter resistance. The long history and protracted
controversy surrounding the wastewater project was supposed to address groundwater
management as well. A holistic approach to groundwater management was bifurcated
intentionally when the County uncoupled water from wastewater in 2007.
The Basin Plan has many flaws and in part is built on two plans that are also flawed; the
County’s Water Conservation Plan and its Recycled Water Management Plan. Both plans have
inherent errors that will plague future plans if relied on as the Basin Plan does. As you know, the
County’s Water Conservation Plan falls short in many ways. Nearly a year into its
implementation, according to the LOWWP Monthly Updates, it is evident that very few residents
have taken advantage of the “incentives” to further save water. Less than 4500,000 have been
spent on rebates to date. Additionally and maybe more importantly, the Recycled Water
Management Plan as currently proposed contracts executed to date, only provides water to
agriculturalists that are not currently using Los Osos Groundwater Basin supplies. The recycled
water used will grow crops on land that currently is not irrigated, providing no seawater intrusion
mitigation.
The Basin Plan contemplates a Facilities District and Water Master to manage the
program/s implementation. Another Board, staff, and bureaucracy to do what really only the two
major purveyors need to agree to. The County and S&T Mutual are bit players in the overall
scheme of basin management. Once the LOWWP is operational, the County’s only role in water
management will be its nexus to land use permits. Its role is already in place with the ordinances
From the Desk of Julie Tacker
PO Box 6070
Los Osos, CA 93412
805-528-3569
for water conservation and new wells needing metering. S&T Mutual’s role/percentage of use
continues to be reduced since their installation of individual meters.
With regard to the programs as outlined in the Basin Plan, priorities should be set with
the least cost and maximum benefit because the lion’s share of the LOWWP has burdened the
developed properties to date. Additionally, as far as choices go, while I personally do not like
the importation alternatives associated with Nacimiento and State Water, I do believe that the
ratepayers should be informed of the choice of spending their funds for sources that have been
reliable for other communities. Imported water may be favored over the experiments laid out in
the Basin Plan that may fail, and have to import water anyway. In essence, paying twice.
Equity issue’s has long been at the center of controversy, years of costs burdened by the
Prohibition Zone. But for as these many years’ general property taxes (approximately $180,000
annually) have been subsidizing rates at the LOCSD Water Company. These funds should be
looked at as a source to cover costs of basin management rather than continue to subsidize
LOCSD ratepayers only. This could eliminate the need to form an assessment district or reduce
the assessment overall if these funds could be used to benefit all.
Additional equity issues relate to ag land farmers paying only $100 per AF verse the
school district (taxpayers) paying upwards of $1,500 per AF. Until these imbalances are
recognized, the ‘salt in wounds’ will continue.
The highest cost project, centralized Nitrogen Removal at the Rosina Well site has
environmental problems that will invoke controversy. The industrial nature of trucks frequently
hauling brine from an area so near the Monarch Grove Elementary School will have traffic
impacts in a school zone. You are also aware, that I do not support using the upper aquifer as a
drinking supply due to the many known contaminants that can/will not be treated as part of its
use.
I look forward to implementation of projects that will balance the basin and will
participate as each one moves forward through the CEQA process.
Thank you for the opportunity to comment.
Sincerely,
Margaret,
Here are my comments regarding the Basin Plan:
Section 1.3.4 Page 8 bottom paragraph states the County will deliver water to the Purveyors for
resale to users. The Plan should define who these users are (the schools). The wastewater
contractors are laying reclaimed water lines in the ground en route to the schools. The Plan
should state this. The way it is currently written is too vague. The term “users” makes it sound
like any homeowner can hook up to the reclaimed water line and use it.
Section 5.8 Page 83: The nitrate level illustrations do not indicate what measurement is being
indicated indicated. (i.e. mg/L). Although there are numbers listed in the legend, the
measurement should also be listed to make the illustrations clearer to interpret.
Section 6.1 Page 91 bottom paragraph: Grammar error in the 1st sentence: “This Chapter 6
defines the nitrate…” Should read: “This Chapter defines,” or “Chapter 6 defines.”
Section 7.4.5 Page 127 1st paragraph, 6th line: Grammar error: “A well with an historical
monitoring……” Should read: “A well with a historical monitoring…..”
Section 11.3 Page 244 regarding storm water capture: The idea of connection of a centralized
storm water collection system to privately owned septic tanks abandoned after construction of
the LOWWP and perforation of septic tank floors should be eliminated from the Basin Plan.
Residents are not going to approve of their yards and streets being excavated a second time
after connection to the collection system currently being installed.
Section 11.5.4 Page 251: Typo: Montana Del Oro is incorrect. Should be Montana De Oro.
Lastly, the way the draft is written the County appears to be accepting little or no responsibility
for allowing this crisis to climb to this level. This situation should never have been allowed to
occur and it started decades ago, long before the formation of the LOCSD. The County issued
building permits for nearly every structure in Los Osos and was aware of the looming water
crisis. The issuance of these building permits should have stopped long ago, but the County
failed to do so and should be held equally responsible for the cost of implementing the Basin
Plan.
Thank you,
Jason
Margaret,
Can Marie Smith submit the following questions via email for the ISJ?
Rob
-----Original Message----From: Marie Smith [mailto:[email protected]]
Sent: Friday, September 06, 2013 7:25 AM
To: Rob Miller
Subject: the water basin questions keep coming!
Hi Rob,
I have a lot going on right now and since I really do not know what "cautions" are in the water
plan and haven't had time to read the documents, I would like to leave some more questions
with you to ponder/forward or submit them as comments to the plan if appropriate.
To my previous question which occurred when the subject was about the placement of the
dewatering water that is coming from the sewer installation of pipes/pump stations: what are
the consequences on where we put that water if we haven't considered each particular source
location, the composition of that dewatering water: i.e. if that water was put at the Broderson
leachfields could there be a possible clogging of those lines with salts, oil and grime?
I now add:
Questions arise when considering drilling and using wells to the East:
1. Will this create a false sense of security since the salt water plume will not then be an
immediate threat to the new wells, and will this lead to more water usage by current users and
more population buildout/usage than the water basin can handle?
2. Will this affect nearby private well users or lifeforms?
3. Will there be more of a threat to our water from the nitrates and chemicals from the farms
and also from the old LO Turri road dump plume?
4. Since this will be taking water from a new location, how will this affect the flow of water to
the Bay fringe and other lifeforms?
5. and two general questions: How does the LO earthquake fault line(s) or any underground
springs affect all of this?
It is "interesting" that we are asking the farmer's to decrease their "straw" usage and yet we will
be increasing ours.
I do understand that these issues are complex due to the way that water is moving through the
different soil/solid compositions, the various formations of the clay lenses, and the different
incoming fluid/gas/solid substances.
Thank you for your time and have a great day!
Marie
Ms. Falkner,
It took me a few hours, but I did manage to wade through the 300 page draft Basin
Plan. An advanced degree in geology would have helped through much of the plan. I
accept the need to mitigate the nitrate problem in the Upper Aquifer and salt water
intrusion in the Lower Aquifer That said, I do not recall any discussion relating to the
cost of such efforts during the debate leading up to the adoption of the
LOWWP. Which means another bond issue, this one for about $30 million, will be
forced upon us by the various unelected boards and commissions which run our
lives. And of course, by the time the program is finally finished, the cost will have risen
considerably. My realtor some how never mentioned anything about sewer costs or water
problems when we purchased our home here in 1995. Oh well. One question; will
the vote to adopt a No Further Development or a Buildout Development plan involve the
entire community within the Plan area or only portions thereof? Thanks for your time
and efforts.
William Farmer
1541 4th Street.
November 9, 2013
ISJ Parties,
Here are copies of corrected/updated versions of my comments
submitted in draft form on October 3. I've included a version with the
changes highlighted. Please refer to the three reviews of Basin
conditions by Peter Mayer and Eugene Yates attached to the September
draft of my comments.
Keith Wimer
Summary of Problems with the Draft Basin Plan for the
Los Osos Groundwater Basin (dated 8/1/13) and
Recommended Changes/Actions
Prepared by Keith Wimer 10/2013
Overview of problems and recommendations
In general, the Draft Basin Plan (Basin Plan) down plays the seriousness of the seawater
intrusion problem in the Los Osos Groundwater Basin (the Basin) and overestimates the
potential for the Plan's proposals (recommended programs) to stop and reverse it. This is
largely because the Plan relies too heavily on a Basin model that projects overly-optimistic
Basin yields from the relocation of wells (i.e., Infrastructure Programs A-D). As proposed,
Basin Plan solutions will be too little too late to solve the severe seawater intrusion
problem-and only "kick the can down the road" for others to fix when it is too late to save
the Basin. Because The County, local water purveyors, and key agencies have delayed
effective Basin management and real solutions for 40 years, the Basin's freshwater capacity
has been seriously reduced and remedial actions now must be bold, decisive, and immediate.
(The Basin Plan acknowledges that the Basin has been over drafted since 1979-34 yearsat an average annual rate of 700 to 1100 acre feet per year, 30% to 40%.) Because Los Osos
has been forced to put virtually all of its financial eggs in one basket with the Los Osos
Wastewater Project, Basin Plan programs must also be the most cost-effective possible.
While the basic actions recommended in the Basin Plan (relocation of wells, water-use
efficiency, and recycled water use) are likely to be the most cost effective actions, the Plan
does not maximize them. The benefits of Basin Plan programs are overstated and the
potential for better programs ignored. Further, the Plan does not acknowledge the need for
urgent action, nor support it with time-specific objectives and mechanisms to ensure rapid
implementation. In fact, the Basin Plan does not guarantee any action will be taken. A Basinwide water management ordinance is needed- and provided for in the ISJ agreement-to
ensure quick implementation of the most effective measures. Maximizing cost-effective
water-use efficiency, recycling, and infrastructure programs-and implementing the
programs with a Basin-wide ordinance that requires all water users in the Basin to
participate within the next two years-provides the best chance of reversing seawater
intrusion as soon as possible (S-7 years). As a result, it provides the best chance of
preserving the basin as a sustainable sole water source for the community. The Los Osos
Groundwater Basin must be preserved as the sole sustainable water source for the
community because supplemental water is unreliable and/or infeasible eco nomically,
socially, and technically. Furthermore, preserving the Basin as the sole source is the only
way to begin to justify the tremendous costs and environmental impacts of the LOWWP,
which agencies have required and justified as "essential" for the sustainability of the Basin
and community.
I. The draft Basin Plan does not adequately describe the severity of seawater intrusion
in the Basin or the need for urgent action. The Plan provides an overview of seawater
intrusion's relentless march through the basin since the 1970's and explains that the Los
Osos Groundwater Basin Update (Basin Update) (released by the Parties in May 2010)
showed seawater intrusion had accelerated from an 60 feet per year to 700 feet per year
Wimer comments on Draft Basin Plan, 10/2013, Page 1 of 15
(about 12 times) between 2004 and 2009 (Page 85). Also, the Basin Plan states: "Currently,
and for the foreseeable future, seawater intrusion is the most serous (sic) challenge facing
the Basin," and it includes, as one of three "Immediate Goals," to "Halt or, to the extent
possible, reverse water intrusion into the Basin." However, the draft Plan does not state the
need for "quick and decisive action" as the Parties stated in the 2010 Basin Update-nor
does the Basin Plan state how destructive seawater has been and will continue to be without
bold, decisive, immediate action.
In a review of the seawater intrusion problem in 2010, Eugene Yates, a foremost authority
on the Basin, called the problem "extremely urgent," and recommended an aggressive wateruse efficiency program, agricultural exchange, and low impact development/rechargealong with major shifts in pumping to the Upper Aquifer and inland within two years. He
said the actions were needed to raise the water tables in the Lower Aquifer to above sea
level as soon as possible to reduce the threat to the water supply. He added that seawater
intrusion destroys water for most uses at very low concentrations and is very difficult to
reverse once it advances. He also warned that LOWWP impacts on the Upper aquifer, in
conjunction with necessary shifts in pumping to the Upper Aquifer, could cause seawater
intrusion in the aquifer. (See Yates 8/2010 review, e.g., Page 1 & 6, attached.) In addition
to maximizing conservation and other programs, he recommended having contingency
measures in place, if seawater intrusion results from the major changes planned for the
Basin. The Basin Plan lists one of Mr. Yate's reviews from 2010, but cites neither.
The 2010 Basin Update showed seawater intrusion was advancing about 700 feet per year
between 2004 and 2009 and had accelerated by 12 times. Instead of explaining the serious
implication of this rapid advance, the Basin Plan states "...while accelerated rates of
intrusion since 2005 have occurred, they may not be as high as rates calculated in 2010."
The Plan then provides a cross-sectional diagram of the Basin showing seawater in Zone D
had not reached the Palisades Well as the Basin Update reported (Page 85). However, the
Basin Plan does not provide an estimate of how fast seawater intrusion is moving inland.
Figure 26 (Page 86), when examined closely, shows that intrusion into Zone D along a broad
front at the seawater interface moved about twice as far in four years as it had in the
previous 20 years. In other words, seawater intrusion moved 10 times as fast, rather than 12
times as fast (500-600 feet per year). The Basin Plan plays down the severity of the problem
by not clearly stating this fact.
Seawater intrusion into Zone D along a broad front, rather than along preferred pathways
("fingers" extending into Zone D to the Palisades well) is caused by low water tables in Zone
D. The Basin Plan points this out, but then confuses the issue. It states
In order to maintain the freshwater-seawater interface at a defined location in the
Basin, average static groundwater levels in the freshwater portion of the aquifer must
be held higher than sea level. Iffreshwater levels fall below a certain level (defined in
more detail below)_ then seawater will progress inland in order to equilibrate the
pressures between seawater and freshwater portions of the aquifer. (Page 98)
This acknowledges that seawater intrusion will continue until water tables are brought up in
all of Zone D, but the Basin Plan then states:
In order to control seawater intrusion in the Basin, the Purveyors and other
groundwater users need to reduce their production from the Lower Aquifer in the
Western Area. That action will allow freshwater levels to rise, thereby preventing
further seawater intrusion and pushing the freshwater-seawater interface seaward
and away from the Los Osos community. (Emphasis added)" (Page 98)
This statement gives the impression that sh ifting pumping in ZoneD from the Western Area
to the Central Area will stop seawater intrusion. However, the strategy is designed primarily
to stop localized intrusion and to create a freshwater "barrier" to slow intrusion into the
aquifer along preferred pathways (e.g., into the large pumping depression under the
commercial area). The strategy will not stop the broad front of seawater moving in under
the aquifer, which may still be advancing at the 2005-2009 rate of 500 to 600 feet per year.
This front can only be stopped by bringing up water levels in Zone D to 8-9 feet above sea
level, which requires reducing pumping enough in all Zone D wells to eliminate the large
pumping depression, which extends "throughout the Central and Western Areas," according
to the Basin Plan (Page 66). The fact that seawater intrusion will co ntinue (and the reasons)
are explained on Pages 84 and 85 of the Basin Plan, which, at one point states, "Given that
Lower Aquifer groundwater elevations inland of the coast have been below sea level or
within a few feet of sea level for many years, seawater intrusion was inevitable" (Page 85).
The Basin Plan also fails to mention that seawater intrusion permanently destroys the Basin
as it advances. The 2005 Seawater Intrusion Assessment by Cleath and Associates (now
Cleath-Harris Geologists, Inc.) indicates that, when chloride levels reach 2500 mgjl,
seawater intrusion is not reversible. Figure 9 of the Assessment shows how much of the two
Lower Aquifers (Zones D & E) had been destroyed between 1985 and 2005. However,
neither the 2010 Basin Update, nor the draft Basin Plan, shows how much permanent
destruction of the Basin has occurred since 1985.
The Basin Plan also does not clearly describe the state of Lower Aqui fer Zone E (the deep
aquifer). Based on responses by Rob Miller of Wallace Group to questions asked at an
LOCSD special meeting on the Basin Plan, purveyors are not pumping from Zone E, except
from one inland well, due to severe seawater intrusion. The Basin Plan refers to Zones D and
E as a single aquifer (calling them the "Lower Aquifer"); however, the Plan reports that Zone
E was sealed off at a main community supply well (Palisades Well) due to chloride levels
above safe limits, and it refers to Zone E as a source of seawater for desalination. It adds that
total dissolved solids (TDS) levels in Zone E exceed the levels of brackish water (1,000 mg/1
to 10,000 mg/1) (Page 24 7). TDS levels are typically roughly double chloride levels. The fact
that chlorid e levels are not presented for Zone E suggests the Plan is avoiding the issue. As
stated, seawater destroys the Basin when chlorides reach 2500 mg/1, and the Title 22 safe
lim it for chlorides in drinking water is 500 mgji. At the LOCSD meeting, Mr. Miller
acknowledged that the Parties were "not trying to save Zone E." The deep aquifer once
comprised over 1/3rd of the basin's freshwater capacity and contained its purest water,
5,000 to 10,000-year-old "fossil water," unpolluted by nitrates and other contaminants. It
showed no signs of seawater intrusion in the 1970's.
If Zone E is no longer a viable drinking water source, a major concern is whether the Basin
has enough capacity to sustain the curren t population; another concern is the extent to
which severe intrusion in Zone E will affect Zone D since the Basin Plan describes the
aquitard (clay layer) separating the aquifers as "possibly discontinuous" (Page 64).
Further, the Basin Plan does not estimate how long it will take to raise water levels in Zone D
enough to reverse seawater intrusion, or how much more of the basin will be destroyed by
that time. Currently, three-fourths of the urban water supply is pumped from Zone D, and
the Basin Plan acknowledges pumping levels are not sustainable. It estimates 460 AFY of
pumping must be shifted from ZoneD in the Western Area to ZoneD in the Central Area, and
to the Upper Aquifer to achieve "sustainable" conditions. However, a "sustainable"
condition, as defined in the Basin Plan is a condition in which no active well has a chloride
level above 250 mg/1. Therefore-as acknowledged in the Plan-"sustainable" defines a
condition in which seawater advances much further into the basin. This additional progress
is seen when Figure 27 is compared to Figure 38. Although the Basin Plan provides a map
showing where seawater would stop under "sustainable" conditions, it does not estimate
how long this condition will take to achieve. A 2009 report prepared by Cleath-Harris for
the Parties ("Flow Model Conversion and Urban Area Yield Update" by Spencer Harris of
Cleath-Harris Geologists, Inc.") predicts "sustainable" conditions based on "SO and 500-year
snapshots," but that report assumes much different "sustainable yields" (much lower yields
for Zone D and much higher for Zone C, the Upper Aquifer). Thus, Basin Plan "sustainable
yields" are questionable to begin with. At best, they would not stop seawater intrusion for
several decades. (See 2009 report by Cleath-Harris, Pages 5 & 6, attached and Parts II).
The draft Plan estimates that recommended Infrastructure Program AC will take about three
years to construct and another five years before the first signs of rising water tables are seen
(Pages 106 and 238). It also estimates it will take 15 years for chloride levels to drop, once
the aquifer levels are high enough to reverse intrusion (8 feet above msl) (Page 106). Thus,
if seawater continues to move inland at the 2005-2009 rate (about 1/2 mile every 4-5
years), it could progress another mile into the Basin even before the first signs of rising
water levels (about eight years), and it could travel two miles or more inland before the
contamination of freshwater by seawater shows the first signs of reversing-assuming the
programs are effective. The Western and Central Areas of the Basin extend only about two
miles from where the seawater intrusion front was last measured in Zone D--even with
Broderson Avenue (see Figure 26). Therefore, at the 2005-2009 rate of seawater intrusion,
Zone D could be destroyed by seawater before the Basin Plan predicts intrusion will show
signs of reversal (i.e., in 15 years or so).
The Basin Plan recommends adding a 20% margin of safety to "sustainable" yields to
account for uncertainties (i.e., reducing production to 20% below these yields), and it states
that the margin will push the seawater interface offshore. Undoubtedly the margin increases
the likelihood of reversing seawater intrusion, but the Plan does not estimate when seawater
will be reversed under any scenario-and the margin of safety is not likely enough to
reverse seawater intrusion (see Part II).
Two other facts presented in the Basin Plan show how severe the problem is and how
difficult it will be to reverse. The Basin Plan estimates total freshwater storage capacity of
the Basin at about 205,000 acre feet (AF), 140,000 AF in the Lower Aquifer and 65,000 AF in
the Upper. It says only 40,000 AF are above sea above sea level (can be pumped without
inducing seawater intrusion) almost all in the Upper. It adds that the storage above sea level
provides a sufficient buffer against seawater intrusion during droughts, given annual
community water use under 3,000 AF. However, the 2003 Yates and Williams study
estimates total Basin storage at about 500,000 AF (452,000 AF in the Lower Aquifers and
37,800 AF to 50,400 AF in the Upper Aquifer). Unless one of the studies is way off in its
estimate, the difference could mean that over half of the Basin's freshwater capacity has
been rendered unusable by seawater intrusion.
Also, the Basin Plan reports that the community reduced water use by almost 40% since
about 1988 (Page 140). This is good news because the large reduction has brought
production in the Basin down much closer to a true safe yield. (The safe yield of the Basin
has been overestimate by 700 to 1000 AFY for at least 15 years (3,200 to 3,500 AFY versus
the 2450 AFY per the Basin Plan), and the Basin has been over drafted by over 700 AFY on
average for 34 years. It is bad news because seawater in trusion has continued although
conservation is widely recognized by experts as the most cost-effective and immediate way
to reduce seawater intrusion (since it reduces the pumping causing it and allows water
levels to rise). The fact that rapid seawater intrusion continues with almost a 40% water use
reduction shows how difficult seawater intrusion will be to reverse, and it means there is
much less conservation potential to do it with. Undoubtedly, so much conservation would
have had a greater effect on seawater intrusion if, at the same time, more pumping had been
shifted away from Western Area in Zone D, but it remains to be seen if enough conservation
potential still exists to bring up low water tables in Zone D (the large pumping d epression
under much of the community) without over pumping Zone C or other parts of the Basin.
One fact is certain-all of these programs must be maximized to optimize flexibility and the
potential for success.
Recommendations:
1. Accurately describe the threat of seaw ater intrusion to the Basin by explaining the
conditions above.
2. Acknowledge the need for urgent, decis ive action so that more of Basin is not destroyed.
3. Present scenarios/programs to bring water tables up in all of Zone D to an average of 8
feet above mean sea level (msl) as soon as possible and project how long each will take to
meet th e objective.
4. Stop pumping altogether from Zone E, analyze its potential adverse impacts on Zone D
(from very high salt levels and a discontinuous layer separating the aquifers), and devise
a plan to save Zone E. Present scenarios/programs to bring water tables up in the
aquifer an average of 17 feet above mean sea level (msl) as soon as possible and project
how long each will take to meet the objective.
5. Expand water level and chloride metrics to include wells measuring changes in the
pumping d epressions of all production zones (Zones C, D, and E) - and change the
chloride metric to 60 mg/ 1 (much closer to historic chloride levels than the proposed 100
mgjl, which indicates continued seawater contamination). (The water level metric for
Zone E will have to be near 17 feet above mean sea level.)
6. Implement enhanced conservation and reuse progra ms tha t maximize seawater
intrusion benefits by maximizing pumping reductions in the Western and Central Areas
(see recommendations below)-also include an enhanced infrastructure program
(Implement Program D with the recommended Program AC as a first step).
7. Target a reduction in pumping in the Western and Central Areas of the Basin to no more
than 1000 AFY within two years. [Target 0 AFY pumped from Zone D in the Western
Area, 400 AFY pumped from Zone D in the Central Area, 500-600 AFY pumped from the
Upper Aquifer in the Western and Central Areas (with Program AC), and 300-400 AFY
pumped from the Eastern Area (via Program D). This would make total production for
the urban population about 1400 AFY, near the 1450 AFY recommended in the Basin
Plan (Page 6), also maintaining the current production for agriculture at 750 AFY. With
this scenario, total production for the Basin would be about 2150 AFY, about 300 AFY
(1 2%) under the Basin Plan's "sustainable yield" for current conditions (2450 AFY) a nd
Wimer comments on Draft Basin Plan, 10/2 013, Page 5 of 15
190 AFY (10%) over the "sustainable yield" with a 20% margin of safety for current
conditions (1960 AFY). This approach applies a 20% margin of safety (as the Basin Plan
recommends) but reduces reliance on the Model by assuming shifts in pumping with
Infrastructure Programs ACD increase Basin yield by about 10%, rather than 20-40%.
The 1000 AFY target within two years for the Western and Central Areas should
maximize the potential to bring up water tables in Zone D, while not adversely impacting
Zone C-thus, maximizing the chance of reversing seawater intrusion as soon as possible.
This scenario does not use all the potential of Program D, leaving 200-300 AFY of
estimated yield as a buffer and to adapt to adverse impacts (e.g., LOWWP impacts). (Also,
see Part 2 below for why these assumptions and the approach are needed.)
II.
The Plan relies too heavily on a Model with substantial uncertainty and a questionable
finding/assumption that moving production in Lower Aquifer Zone D to the Upper
Aquifer and inland will increase basin yield significantly.
A main focus of the Plan is to move more pumping inland in ZoneD and to the Upper Aquifer
with infrastructure programs. The Plan estimates Infrastructure Program AC will increase
the yield of the basin to 3000 AFY from 2450 AFY, and it estimates that adding Infrastructure
Programs B and D to Program AC will raise "sustainable yields" to 3500 AFY (Pages 237 &
239). Eugene Yates, however, is clear that shifts in pumping do not increase basin yields
long-term. In a January 2010 review of Basin yields (entitled "Review of Cleath-Harris
Geologists' July 2009 Memorandum 'Flow Model Conversion and Urban Area Yield Update"'),
Mr. Yates states
The proposed management actions to address the saltwater intrusion problem do not
increase basin yield, but shift the location of groundwater extraction. For example,
pairing shallow and deep wells at major pumping locations provides the opportunity
to adjust the proportion of water pumped from the upper and lower aquifers but it
does not increase yield. Furthermore, there are limits to this strategy because of the
uncertainty in the capacity of the upper aquifer to support additional extractions and
the possibility of seawater intrusion occurring in the upper aquifer. (See Yates 1/13/
2010 review, Page 4).
In an August 2010 review of the Basin Update (entitled "Review of Los Osos Basin Update
and Current Wastewater Project Description-Revised"), Mr. Yates points out that seawater
intrusion is mainly a problem of basin imbalance ("more water consumed in the basin than
being replenished") and he recommends maximizing indoor-outdoor conservation, storm
water recharge, rainwater harvesting and low impact development recharge to tip the
balance toward more water entering the basin than leaving it (see Yates 6/10/2010 review,
Page 1).
Mr. Yates points out (and the Basin Plan agrees) seawater intrusion cannot be stopped and
reversed until water levels in the aquifers are above sea level. The infrastructure program
recommended in the Basin Plan (Program AC) involves moving most pumping inland to the
Central Area, but maintaining most of the pumping from ZoneD (1260 AFY ZoneD vs. 950
Zone C-Page 237). Water levels in Zone D are already low throughout the Western and
Central Areas (Page 64). The assumption that shifting more pumping inland in ZoneD will
increase yields and bring water levels up in the aquifer is not credible-especially when the
recharge regime and structure of the Basin are considered. Virtually all recharge of the
Wimer comments on Draft Basin Plan, 10/2013, Page 6 of15
Lower Aquifer in the Western and Central Areas is from the Upper Aquifer, or Lower
Aquifer in the Eastern Area, according to the 2005 Seawater Intrusion Assessment (p. 77).
Also, based on cross sectional maps of the Basin (e.g., Figure 27, Page 87) Zone D tapers up
as it nears Los Osos Creek, indicating that proposed wells will tap the aquifer at higher
elevations. Higher elevations of Zone D undoubtedly supply lower elevations. Whereas
additional wells in the Central Area may increase yields incrementally (i.e., allow extraction
of some additional water flowing toward the estuary or creek), most of the groundwater in
the Central Area apparently flows west to lower parts of the Basin. Therefore, additional
inland Zone D wells (e.g., Program C) are not likely to produce a significant net increase in
yield or bring up water levels significantly. It is just as likely to lower water levels and pull
seawater further into Zone D and/or cause adverse impacts on private wells or sensitive
habitat in the area.
The prediction in the Basin Plan that moving production inland and to the Upper Aquifer
will substantially increased yields is based on the Basin Model, with substantial margins of
error. Based on a peer review of the Model, the Basin Plan says the Model has been found
to be a good basis for determining yields and the rate of seawater intrusion (Page 77).
However, Mr. Peter Pyle, of Stetson Engineers, chooses his words carefully in his review of
the Model (which is included in the 2010 Basin Update.) According to the Basin Plan, Mr.
Pyle says that the Model is okay to use to "initiate" changes so long as changes are "gradual"
and there are monitoring and contingency plans in place. He also states that the "structure"
of the Model is "sound and able to simulate hydrologic processes in the Basin, particularly
as regards to the ... extent of seawater intrusion in each of the main water bearing units
(Zones C, D, and E)," but he recommends refinements in the Model and he does not say the
Model is able to accurately predict the extent of seawater intrusion now-and for good
reason. The technical memorandum entitled "Flow Model Conversion and Urban Area Yield
Update" by Spencer Harris of Cleath-Harris Geologists, Inc. (2009)-which introduced the
latest version of the Model and first estimated "sustainable yields" based on the Modelreports that the Model underestimated seawater intrusion progress in Zone E by 1000 to
2000 feet per year (see Cleath-Harris TM "Urban Yield," Page 4, attached). More recent
information in the Basin Plan reveals the inaccuracy was even greater because seawater
intrusion in Zone E had moved even faster. The Basin Plan states " ... a back calculation of
historical water quality data shows that the intrusion front in Zone E had already reached
the Palisades Well by 2005," which required changing the " ... historical rate of seawater
intrusion in Zone E between 1977 and 2005 " .. .from 54 feet per year to approximately 180
feet per year" (Page 85).
The Basin Plan also fails to mention that Mr. Pyle wrote his review without the benefit of the
2010 Basin Update (and the Cleath-Harris technical memorandum contained in the Update),
which first revealed that seawater intrusion had accelerated by at least 10 times in Zone D
between 2005 and 2009. In other words, in 2009 the Model was at least a 1000% off in its
simulation of the rate of seawater intrusion, showing "an average velocity of 60 feet per
year" when it was closer to 700 feet per year (Page 4).
The Basin Plan acknowledges there is a good deal of uncertainty in the Model and it
mentions some of the sources. However, it leaves out some of the sources Mr. Yates lists in
his 2010 review of the Cleath-Harris 2009 technical memorandum. Eugene Yates, one of the
creators of the Model, cites one source that could result in an error of 40% in yield estimates
(see Yate's 1/13/10 review, Page 3). He expresses particular doubts about the Model's
ability to predict yields with the combined impacts of the LOWWP and a lot more pumping
from the Upper Aquifer (a condition unlike any in the basin's history). He also cites the
possible use of potable water for habitat restoration to mitigate LOWWP impacts on
wetlands as a source of error, and he points out that Broderson leach fields will not restore
groundwater flows to some habitat along Morro Bay Estuary (see Yate's 1/13/10 review,
Page 4) . The LOWWP is likely to stop at least 300 AFY of groundwater flows to Morro Bay
Estuary and sensitive habitat (the difference between eliminated septic system flows, 780
AFY, and the groundwater Broderson and Bayridge leach fields is supposed to replace, 480
AFY). There is no LOWWP project document that makes it clear how this water will be
replaced if necessary to avoid adverse impacts on habitat.
To account for uncertainties in the Model, the Basin Plan recommends adding a 20% margin
of safety to yields (targeting yields of 80% of "sustainable yields" as determined by the
Model), and it states the margin will also result in reversing seawater intrusion. However,
the Plan does not say how it arrives at the 20% margin-and 20% is not likely enough to
account for uncertainties-let alone reversing seawater intrusion.
One fact supporting the need for a larger margin of safety and less reliance on the Model is
that Cleath-Harris has had to revise down basin yield estimates for current conditions from
about 3,500 AFY in 2000 to 3,200 AFY in 2009, down to 2,450 AFY in 2012 (with the Basin
Plan). (Note that 2,450 AFY is a "sustainable yield," which allows seawater intrusion to
advance substantially further). With the 20% margin applied, under current conditions a
yield of 1960 AFY would be required to reverse seawater intrusion per the Basin Plan. As
the Plan points out, the "sustainable yield" has been exceeded since 1979 (34 years) by an
average of 700 AFY or 30%, and it has been over drafted by 1100 AFY if the safer yield
estimate of 80% of sustainable yield is applied. The total overdraft is 23,800 AF to 37,400
AF or 10 to 15 years of water use in the Basin as "sustainable yield" levels. This longstanding overdraft, which resulted in much of the Basin being destroyed-is due to modeling
error. More fundamentally, it is due to an over reliance on the Model and a tendency for
decision-makers to support overly-optimistic projections of Basin yield (i.e., to err on the
side of maximizing production rather than sustaining the Basin).
In 2009, Cleath-Harris drastically changed the yield estimates for the Upper and Lower
Aquifers. Estimates for the Lower Aquifer in the Western and Central Areas of the Basin
were cut in half to between 600 and 725 AFY from 1300 AFY, and "safe" yield for the Upper
Aquifer was increased from 1150 AFY to about 1450 AFY, indicating that the Lower Aquifer
yields had been overestimated by 600-700 AFY and Upper Aquifer yields underestimated by
300 AFY for many years. The Cleath-Harris safe yield estimates for the Upper and Lower
Aquifers are taken from the 2007 Resource Capacity Study, Page 9.
Finally, the "sustainable yields" based on the latest version of the Model, which Cleath-Harris
presents in 2009 in the "Flow Model Conversion and Urban Area Yield Update," are different
from the yields Cleath-Harris presents in the Basin Plan based on the same version of the
Model. The 2009 memo estimates "sustainable yields" for water purveyors from the Lower
Aquifer (with the LOWWP) at 725 AFY and Upper Aquifer yields 1325 AFY (see ISJ TM
"Urban Yield," p. 8). The Basin Plan estimates "sustainable yields" with the LOWWP at 1160
AFY for the Lower Aquifer and 580 AFY for the Upper Aquifer (Page 226). This is 435 AFY
(or 60%) more than the earlier Cleath-Harris estimates for the Lower Aquifer.
According to the Basin Plan, all pumping options (i.e., Infrastructure Programs A, B, C, & D)
will produce greater "sustainable yields" from the Lower Aquifer than the 2009 CleathWimer comments on Draft Basin Plan, 10/2013, Page 8 of15
Harris technical memorandum estimates-even though the 2009 memorandum also
assumes there will be changes in pumping locations (see ISJ Urban Yield, p. 5 and Basin Plan,
pp. 226-233).
If the Model, including the latest version by Cleath-Harris, cannot consistently and accurately
predict the yields of the aquifers, there is no reason to believe it can predict variations in
yields (including much higher yields) when pumping is shifted to specific locations within
the aquifers.
As explained in the 2009 Cleath-Harris technical memorandum, "sustainable yields" are
basically theoretical conditions that would develop 50 to 500 years out, assuming the Model
is exactly accurate and past conditions match future conditions perfectly (i.e., there are no
droughts, no changes in weather patterns, and no LOWWP). The Basin Plan warns of
potential harm to the Basin from not monitoring private wells and applying inaccurate water
use estimates in the Model, and it points out that the error might not be known for 15 years
or more, when it is too late to undo the damage. The same observation applies to modeling
errors.
Because there is no room for error with the Los Osos Valley Water Basin, sustainable yield
estimates and production targets should be substantially lower than the 80% of current
"sustainable yields," as proposed in the Basin Plan. Also, Infrastructure Programs ACD
should be put in place to buy time, optimize safe production, and allow adaptive
management (flexibility in where production occurs) to maximize benefits to the Basin.
Recommendations:
1. Add a 30% margin of safety to current "sustainable yields" to arrive at truer sustainable
yields (and/or) recalibrate the Model to calculated safe yields, such that no production
well has a chloride level exceeding the historical chloride level of 60 mgjl.
2. Apply the revised definition of "sustainable yield" (from #1 above) and "sustainable"
Basin conditions" throughout the Basin Plan. Eliminate all references to "sustainable
yields" and "a sustainable Basin," which use the "no more than 250 mgjl of chlorides"
criterion.
3. Limit yield estimates for the Basin to four: one each for the Upper and Lower Aquifers in
the Western and Central Areas of the Basin (west of Los Osos Creek) and one each for
Upper and Lower Aquifers in the Eastern Area (east of the Los Osos Creek).
4. Implementation Infrastructure Programs ACD immediately and assume no more than a
10% increase in yield from the Western and Central Areas with the.
5. Rely less on the Model and more on basic principles: 1) that the water levels in Zones D
and E must be brought up to above sea level as soon as possible, and 2) this requires
tipping the balance towards substantially more recharge than extraction with a large
margin of safety. (The larger the margin of safety, the less of the Basin is lost and the
more likely it is to be sustainable).
6. Upgrade the Model and continue to refine it based on actual well tests.
(See Part I for further sustainable yield recommendations.)
III.
The Plan does not commit the County and purveyors to take urgent action, or any
action, and a Basin-wide ordinance is needed. Although the Basin Plan recommends a set
of programs for the Parties to implement, the Basin Plan does not commit the Parties to any
specific action, especially urgent action.
The Plan is basically a set of goals with recommendations reflecting the same general
recommendations presented in every draft management plan and agency review of the Basin
for 40 years-i.e., relocating wells and intensive conservation. The Basin Plan states in
several places that the Parties are deciding what actions to take and haven't agreed on any.
It also recommends that funding for actions comes from a general assessment on the
Community of Los Osos, but the community is likely to reject an assessment due to large
assessments for the LOWWP, which are causing steep increases in property taxes.
The Parties have been very slow to implement well relocations and aggressive conservation
in the past, and have taken five years just to negotiate the draft Basin Plan although it was
their stated goal the ISJ to have the Basin Plan fully implemented within 12 months of the
signing of the agreement in August 2008 (see IS], Page 6). The Parties were also supposed to
negotiate and implement an intertie agreement within four months of signing the agreement
(see IS], Page 9), but this is still not done. In 2010 the Parties commissioned a study, which
showed a community nitrate facility would be cost effective, but it was not implemented.
The fact that most of the production in the Basin is still from Zone D wells in the Western
Area and the Parties have not completed the above actions is a good indicator of the Parties'
level of commitment to stopping seawater intrusion and it bodes poorly for the future. In the
2010 Basin Update, the Parties state the need for "quick and decisive action," but the Basin
Plan doesn't restate or convey that need-and the level of action taken so far does not reflect
the level of commitment needed to address the severe problem.
While the Plan sets an "Immediate Goal" of halting and reversing seawater intrusion, it does
not identify specific, aggressive objectives and timeframes. It further does not maximize
conservation with a strong outdoor component, nor does it propose an aggressive recycled
water use program. The law and the ISJ agreement under which the Parties are developing
the Basin Plan, allow the County to implement a basin-wide ordinance to implement the
Plan, which could set time-specific objectives for stopping seawater intrusion, but the Basin
Plan does not mention the option. Instead, it indicates that a Water Master under the
Control of the Parties will be appointed to oversee implementation.
The Basin Plan does recommend that the County implements an ordinance requiring private
well owners to report well production, but it rejects an ordinance requiring the same
property owners to conserve water. What is needed is a County basin-wide water
management ordinance, enacted within one year that implements these measures and
others within two years, in order to reverse seawater intrusion as soon as possible (S-7
years).
Recommendations:
1. Support/require implementation of a County basin-wide water management ordinance
to implement maximized Basin Plan measures/programs within one year.
2. Support/require the Basin-wide ordinance to set a time-specific objective to stop
seawater intrusion by fully implementing maximized conservation, reuse, and
infrastructure programs within two years and raising water tables in Zones D and E to
above sea level within 10 years, with targeted benchmarks (e.g., rises in water levels as
measured in metric wells). The ordinance would also include adequate
incentives/enforcement mechanisms to achieve the objectives.
Wimer comments on Draft Basin Plan, 10/2013, Page 10 of15
3. Apply for funding from the State Water Board and other agencies to implement
programs.
IV.
The Basin Plan ignores established facts regarding the structure of the basin.
Since the 1980s, Basin studies have recognized that the Basin east of Los Osos Creek (the
Eastern Area) is a separate compartment, historically referred to as the Creek Compartment,
which functions semi-independently of the part of the Basin west of Los Osos Creek (the
Urban Compartment). As a result, safe yields have traditionally been calculated separately.
The Creek Compartment (or the Eastern Area in the Basin Plan) contributes some
groundwater flows to the Urban Compartment (Western and Central Areas in the Basin
Plan), but a reduction in pumping in the Creek Compartment (Eastern Area) would not be
noticed as an increase in water levels in the Urban Compartment (Western and Central
Areas) for several decades if at all. This is why the LOWWP EIR estimates that the seawater
intrusion mitigation potential of recycled water use in the Creek Compartment is only 1 j5th
or 20% of the Urban Compartment's mitigation value (a 0.1 mitigation factor versus a 0.55
factor). Furthermore, the 1f5th or 20% would be a long-delayed benefit with much higher
levels of uncertainty than mitigation in Western and Central Areas, where recycled water
reduces pumping causing seawater intrusion and immediately mitigates seawater intrusion.
The Basin Plan recognizes that pumping from different locations in the Basin has greater or
lesser effects on seawater intrusion, but it fails to recognize that conservation and recycled
water use in the Eastern Area will have much less benefit on seawater intrusion than the
same programs in the Western and Central Areas. The "Solutions" section of the Basin Plan,
estimates the degree to which various programs achieve target yields, chloride levels, and
water levels as shown by "metrics," but the m etrics and calculations do not factor what parts
of the Basin the programs affect. By failing to distinguish the effects of programs on the
Eastern Area versus the Western and Central Areas, the Basin Plan exaggerates the benefits
of conservation and reuse programs in the Eastern Area on seawater intrusion, and it
ignores the potential for stopping seawater intrusion and managing the Basin sustainably by
redistributing water from the Eastern to Western and Central Areas of the Basin and viceversa. Recognizing that the Basin has two relatively distinct sub-basins is necessary for
maximizing resources and opportunities to achieve a sustainable Basin.
Recommendation:
1. Recognize and build into programs and planning the fact that the Basin has two semidiscrete compartments, one of which is severely impacted by seawater intrusion with
low water tables and the other of which is apparently healthy with excess capacity that
allows additional pumping.
2. Recognize and build into planning the fact that reduced pumping must occur in the
Western and Central Areas to mitigate seawater intrusion significantly.
V.
The Plan overstates the benefits of water recycling programs and ignores the need
and potential for a much stronger program.
The Plan indicates the Urban Water Reinvestment Program (essentially the LOWWP
recycling program) will increase basin yield over current conditions (Pages 279 & 281). The
Plan, therefore, assumes that the combination of recycled water discharged in Broderson
and Bayridge Estates leach fields (up to 480 AFY), the water recycled in the Western and
Central Areas of the Basin (about 100 AFY), and the water recycled in the agricultural area
east of Los Osos Creek (about 200 AFY); will provide greater recharge benefits than septic
systems (i.e., current conditions). However, this assumption is faulty as shown by a simple
calculation of Basin balance, keeping the Basin's structure in mind. The LOWWP removes
780 AFY of groundwater from the Western and Central Areas of the Basin by removing
septic systems, and it returns it only about 580 AFY to the areas. The Basin Plan claims the
program increases irrigation return flows; however, since it does not increase irrigation, it
does not increase return flows (Page 281). The Model may credit Broderson leach fields
with more efficient recharge of the aquifer, which could explain the additional mitigation
benefit; however, the Model is not time sensitive. Broderson leach fields will take more than
15 years to restore flows and Basin equilibrium-if it works as the EIR predicts, which is frar
from certain-so the measure will not effectively offset seawater intrusion for that many
years. In fact, the discharging water in the leach fields results in a significant deficit in water
balance and mitigation (i.e., adverse potential impact on water levels) in the near term. This
adverse impact is compounded by the dewatering program going on now, which removes
recharge from Upper Aquifer.
The Basin Plan also fails to recognize that water recycled in the agricultural areas (Eastern
Area) does not offset pumping significantly in the Western and Central Areas (as described
in Part IV above). Pumping must be reduced in the Basin west of Los Osos Creek to stop
seawater intrusion. The Basin Plan treats the Basin as a single unconfined aquifer when
calculating the benefits of the recycled water program, although the LOWWP EIR and all
Basin studies since the 1980's make it clear that a reduction is potable water use in the
Eastern Area (e.g., via recycling) will have only minor benefits on seawater intrusion, if any
at all.
Without clear justification, the Basin Plan considers Infrastructure Program D (additional
wells in the Eastern Area) only as a source of water to support further development in the
community. It fails to consider the program as a source to help stop seawater intrusion and
mitigate the impacts of the LOWWP. Program D can and should be implemented
immediately along with Program AC for three reasons: 1) to reduce pumping from the
Western and Central Areas to stop seawater intrusion as soon as possible, 2) to offset the
removal of recycled water from the Western and Central areas, and 3) to provide a water
source for adaptive mitigation measures for seawater intrusion and habitat impacts as
needed, e.g., to reduce where and when water is pumped to respond to signs of seawater
intrusion or habitat destruction from the LOWWP and Basin Plan programs). An important
benefit of program D is that it effectively provides an agricultural exchange program-as
recommended by several authorities, including Eugene Yates and the Monterey Bay
Watershed Institute. Basically, Program D optimizes Basin management by maximizing
sources of water.
Finally, the recycled water program can and should be made stronger with the installation of
more purple pipe, especially to parts of the community with larger lots now drawing water
from the Central and Western Areas of the Basin. These properties use water at rates 3 to 4
times that of water users in other parts of the urban area, with most of it outdoors. Use of
recycled water for outdoor irrigation on large lots (about 200 properties now using an
average of about 1 AFY per lot) could reduce potable water use by more than liz AFY per lot
per year (more than 100 AFY).
Recommendations:
1. Implement Program D with Program AC and use the water to offset pumping in
seawater-i mpacted areas, to (effectively) implement an agricultural exchange program
that offsets recycled water applied in the Eastern Area, and to adapt/respond to potential
impacts from major changes in Basin hydrology in the next few years.
2. Install additional purple pipe, especially to parts of the community with large lots
drawing water from the Central and Western Areas of the Basin.
3. Do not assume the Urban Water Reinvestment Program increases Basin yield; instead,
focus on maximizing the program to ensure the water extracted in the Western and
Central Areas and entering the wastewater system is offset either with recycled water or
freshwater from the Eastern Area that replaces recycled water delivered to that part of
the Basin--i.e., be sure be sure the Recycling Program achieves a 1:1 offset.
VI.
The Plan overstates the benefits of the current conservation program and ignores the
potential and the need for a much stronger program.
The Basin Plan stresses the need for a "state-of-the-art" water-use efficiency (conservation)
program to stop seawater intrusion, and sets the goal of achieving such a program (Pages
139 & 147). However, the Basin Plan's proposed Urban Water Use Efficiency Program
(UWUEP) sets conservation targets too low (sets water use targets too high) and overstates
the benefits of the proposed program. It also rejects effective measures, including leak
repair, turf replacement, low-water use landscaping, and rainwater harvesting/recharge
measures such as rain gardens. In general, it backs away from implementing a state-of-theart program even though the public would most likely support it and such program is vital to
stopping seawater intrusion.
The Basin Plan proposes to extend the LOWWP conservation program Basin-wide (adding a
few outdoor measures) to create the proposed "Urban Water Use Efficiency Program." It also
recommends that the County administers the entire indoor-outdoor program until 2018, at
which time Purveyors will take it over. The Plan further recommends that LOWWP
conservation funding ($5 million) is increased to $5.5 million, and shifted from LOWWP
funding to a Basin-wide assessment.
The Basin Plan program, like the LOWWP conservation program, does not maximize
conservation, in large part because both programs rely on a plan the Parties commissioned
by Maddaus Water Management (MWM), which does not maximize conservation. The MWM
Plan sets the water use target too high (50 gpcd indoor by 2015), recommends against
incorporating many effective measures, and extends over too long a time period (until
2035). The MWM plan also exaggerates potential water use reduction in at least two ways:
1) by overstating baseline water use using out-of-date data provided by the Parties, and 2)
by overstating indoor water use versus outdoor use (which results in exaggerated benefits
for the LOWWP indoor program). (See "Los Osos water use and potential conservation
estimates (2012)-draft" by K. Wimer attached.)
The Los Osos Sustainability Group (LOSG) commissioned a review of the MWM plan by Peter
Mayer of Aquacraft located in Boulder Colorado. Aquacraft and Mr. Mayer have done several
conservation end-use studies for the USEPA, including a comprehensive study of California
residential water use. Mr. Mayer concludes that that the MWM plan does not reduce water
use as much as possible, and thus does not maximize seawater intrusion mitigation. Based
on a California-wide survey of water use by Aquacraft for the US EPA, he states that indoor
water use can be reduced to 42 gallons per capita per day (gpcd) with efficient appliances
and fixtures on the market, in addition to leak repair. He adds that a 42 gpcd indoor target
can be easily achieved using the $5 million the County is required to spend to "initiate" the
LOWWP program (i.e., per Coastal Development Permit, Special Condition 5b).
The Basin Plan estimates the proposed program will reduce water use about 300 AFY by
2035. However, the program overestimates the benefits of the program by at least 100 AFY;
whereas a good comprehensive indoor-outdoor program could reduce water use by about
470 AFY (see "Los Osos water use and potential conservation estimates" attached).
Recommendations:
1. Implement a comprehensive indoor-outdoor program with a full range of measures,
including leak repair, low-water use landscaping, rainwater harvesting/recharge, turf
replacement, and grey water reuse.
2. Set the target for indoor residential use at 42 gpcd, with the indoor-outdoor target at 63
to 69 gpcd.
3. Set the baseline target at 80 gpcd Basin wide (Baseline use is calculated by dividing total
use, including residential and CII use, by the total population.)
4. Fund the measures with grants and, if grants are not available, with rate increases so
they can be implemented in the near future. (Later, shift costs to a Basin-wide
assessment.)
5. Apply tiered rates and be sure rate increases reflect the full avoided costs for
supplemental water.
6. Purveyors and the County share in the funding and administration of the program
beginning this year, so that rate increases, if necessary, can cover some of the costs early
on.
7. Enact conservation targets, measures, and incentives with a Basin-wide management
ordinance that has the specific objective of reversing seawater intrusion (per
recommendations above).
8. Implement tiered rates based on individual water budgets, as recommended by Peter
Mayer, in the near future to avoid undue impacts on larger families.
9. Integrate the septic system decommissioningjrepurposing program with the Basin-wide
indoor-outdoor conservation program for efficiency and cost-effectiveness (and consider
having SLO Green build extend its current role to help implement all programs).
VII.
The Plan fails to account for the potential impacts of the LOWWP
The Basin Plan fails to acknowledge or account for potential adverse impacts from the
LOWWP on the Upper and Lower Aquifers. Eugene Yates points out that project impacts are
likely to be greatest on the Upper Aquifer, due the combined impacts of the elimination of
septic recharge and increased pumping from the Upper Aquifer. He did not factor the
adverse impacts from dewatering or the continuing drought. As mentioned, the main
mitigation measure to avoid/minimize groundwater impacts, Broderson leach fields, will not
restore water levels for 15 years or more after elimination of septic recharge, according to
the Monterey Bay Watershed Institute. Although the Basin Plan acknowledges some
"uncertainty" associated with the LOWWP, it does not mention impacts or propose a
contingency plan. Further, it does not assume the LOWWP conservation and reuse programs
will be needed to offset the impacts of the project as intended, but ins tead it assumes the
programs will contribute to stopping seawater intrusion. In fact, the impacts of the LOWWP
on the Upper Aquifer may cause seawater intrusion in that aquifer, and preclude shifting
more pumping to the Upper Aquifer resulting in further destruction of the Lower Aquifer.
The LOWWP is a main reason mitigation programs must be maximized as soon as possible.
If the Basin (e.g., Upper Aquifer) does not survive in the short term, the potential long-term
benefits of the LOWWP (a reduction in nitrates in the Upper Aquifer) will not be realized.
Recommendation:
1. Acknowledge LOWWP impacts and build adaptive measures into the Basin Plan and
Basin-wide ordinance that address impacts (also see recommendations in Parts I and II.)
2. Support stronger mitigation programs for the LOWWP as part of the COP, WDR, and
other permitting requirements.
Summary of Problems with the Draft Basin Plan for the Los Osos
Groundwater Basin (8/1/13)
and Recommended Actions
Prepared by Keith Wimer 10/2013
(Revisions to 9/2013 draft highlighted)
Overview of problems and recommendations
In general, the Draft Basin Plan (Basin Plan) down plays the seriousness of the seawater
intrusion problem in the Los Osos Groundwater Basin (the Basin) and overestimates the
potential for the Plan's proposals (recommended programs) to stop and reverse it. This is
largely because the Plan relies too heavily on a Basin model that projects overly-optimistic
Basin yields from the relocation of wells (i.e., Infrastructure Programs A-D). As proposed,
Basin Plan solutions will be too little too late to solve the severe seawater intrusion
problem- and only "kick the can down the road" for others to fix when it is too late to save
the Basin. Because The County, local water purveyors, and key agencies have delayed
effective Basin management and real solutions for 40 years, the Basin's freshwater capacity
has been seriously reduced and remedial actions now must be bold, decisive, and immediate.
(The Basin Plan acknowledges that the Basin has been over drafted since 1979-34 yearsat an average annual rate of 700 to 1100 acre feet per year, 30% to 40%.) Because Los Osos
has been forced to put virtually all of its financial eggs in one basket with the Los Osos
Wastewater Project, Basin Plan programs must also be the most cost-effective possible.
While the basic actions recommended in the Basin Plan (relocation of wells, water-use
efficiency, and recycled water use) are likely to be the most cost effective actions, the Plan
does not maximize them. The benefits of Basin Plan programs are overstated and the
potential for better programs ignored. Further, the Plan does not acknowledge the need for
urgent action, nor support it with time-specific objectives and mechanisms to ensure rapid
implementation. In fact, the Basin Plan does not guarantee any action will be taken. A Basinwide water management ordinance is needed- and provided for in the ISJ agreement-to
ensure quick implementation of the most effective measures. Maximizing cost-effective
water-use efficiency, recycling, and infrastructure programs-and implementing the
programs with a Basin-wide ordinance that requires all water users in the Basin to
participate within the next two years-provides the best chance of reversing seawater
intrusion as soon as possible (S-7 years). As a result, it provides the best chance of
preserving the basin as a sustainable sole water source for the community. The Los Osos
Groundwater Basin must be preserved as the sole sustainable water source for the
community because supplemental water is unreliable and/or infeasible economically,
socially, and technically. Furthermore, preserving the Basin as the sole source is the only
way to begin to justify the tremendous costs and environmental impacts of the LOWWP,
which agencies have required and justified as "essential" for the sustainability of the Basin
and community.
I.
The draft Basin Plan does not adequately describe the severity of seawater intrusion
in the Basin or the need for urgent action. The Plan provides an overview of seawater
intrusion's relentless march through the basin since the 1970's and explains that the Los
Osos Groundwater Basin Update (Basin Update) (released by the Parties in May 2010)
showed seawater intrusion had accelerated from an 60 feet per year to 700 feet per year
(about 12 times) between 2004 and 2009 (Page 85). Also, the Basin Plan states: "Currently,
and for the foreseeable future, seawater intrusion is the most serous (sic) challenge facing
the Basin," and it includes, as one of three "Immediate Goals," to "Halt or, to the extent
possible, reverse water intrusion into the Basin." However, the draft Plan does not state the
need for "quick and decisive action" as the Parties stated in the 2010 Basin Update-nor
does the Basin Plan state how destructive seawater has been and will continue to be without
bold, decisive, immediate action.
In a review of the seawater intrusion problem in 2010, Eugene Yates, a foremost authority
on the Basin, called the problem "extremely urgent," and recommended an aggressive wateruse efficiency program, agricultural exchange, and low impact development/rechargealong with major shifts in pumping to the Upper Aquifer and inland within two years. He
said the actions were needed to raise the water tables in the Lower Aquifer to above sea
level as soon as possible to reduce the threat to the water supply. He added that seawater
intrusion destroys water for most uses at very low concentrations and is very difficult to
reverse once it advances. He also warned that LOWWP impacts on the Upper aquifer, in
conjunction with necessary shifts in pumping to the Upper Aquifer, could cause seawater
intrusion in the aquifer. (See Yates 8/2010 review, e.g., Page 1 & 6, attached.) In addition
to maximizing conservation and other programs, he recommended having contingency
measures in place, if seawater intrusion results from the major changes planned for the
Basin. The Basin Plan lists one of Mr. Yate's reviews from 2010, but cites neither.
The 2010 Basin Update showed seawater intrusion was advancing about 700 feet per year
between 2004 and 2009 and had accelerated by 12 times. Instead of explaining the serious
implication of this rapid advance, the Basin Plan states "... while accelerated rates of
intrusion since 2005 have occurred, they may not be as high as rates calculated in 2010."
The Plan then provides a cross-sectional diagram of the Basin showing seawater in Zone D
had not reached the Palisades Well as the Basin Update reported (Page 85). However, the
Basin Plan does not provide an estimate of how fast seawater intrusion is moving inland.
Figure 26 (Page 86), when examined closely, shows that intrusion into Zone D along a broad
front at the seawater interface moved about twice as far in four years as it had in the
previous 20 years. In other words, seawater intrusion moved 10 times as fast, rather than 12
times as fast (500-600 feet per year). The Basin Plan plays down the severity of the problem
by not clearly stating this fact.
Seawater intrusion into Zone D along a broad front, rather than along preferred pathways
("fingers" extending into Zone D to the Palisades well) is caused by low water tables in Zone
D. The Basin Plan points this out, but then confuses the issue. It states
In order to maintain the freshwater-seawater interface at a defined location in the
Basin average static groundwater levels in the freshwater portion of the aquifer must
be held higher than sea level. If freshwater levels fall below a certain level (defined in
more detail belowJ then seawater will progress inland in order to equilibrate the
pressures between seawater and freshwater portions of the aquifer. (Page 98)
This acknowledges that seawater intrusion will continue until water tables are brought up in
all of Zone D, but the Basin Plan then states:
In order to con trol seawater intrusion in the Basin, the Purveyors and other
groundwater users need to reduce their production from the Lower Aquifer in the
Western Area. That action will allow freshwater levels to rise, thereby preventing
further seawater intrusion and pushing the freshwater-seawater interface seaward
and away from the Los Osos community. (Emphasis added)" (Page 98)
This statement gives the impression that shifting pumping in ZoneD from the Western Area
to the Central Area will stop seawater intrusion. However, the strategy is designed primarily
to stop localized intrusion and to create a freshwater "barrier" to slow intrusion into the
aquifer along preferred pathways (e.g., into the large pumping depression under the
commercial area). The strategy will not stop the broad front of seawater moving in under
the aquifer, which may still be advancing at the 2005-2009 rate of 500 to 600 feet per year.
This front can only be stopped by bringing up water levels in Zone D to 8-9 feet above sea
level, which requires reducing pumping enough in all Zone D wells to eliminate the large
pumping depression, which extends "throughout the Central and Western Areas," according
to the Basin Plan (Page 66). The fact that seawater intrusion will continue (and the reasons)
are explained on Pages 84 and 85 of the Basin Plan, which, at one point states, "Given that
Lower Aquifer groundwater elevations inland of the coast have been below sea level or
within a few feet of sea level for many years, seawater intrusion was inevitable" (Page 85).
The Basin Plan also fails to mention that seawater intrusion permanently destroys the Basin
as it advances. The 2005 Seawater Intrusion Assessment by Cleath and Associates (now
Cleath-Harris Geologists, Inc.) indicates that, when chloride levels reach 2500 mg/1,
seawater intrusion is not reversible. Figure 9 of the Assessment shows how much of the two
Lower Aquifers (Zones D & E) had been destroyed between 1985 and 2005. However,
neither the 2010 Basin Update, nor the draft Basin Plan, shows how much permanent
destruction of the Basin has occurred since 1985.
The Basin Plan also does not clearly describe the state of Lower Aquifer Zone E (the deep
aquifer). Based on responses by Rob Miller of Wallace Group to questions asked at an
LOCSD special meeting on the Basin Plan, purveyors are not pumping from Zone E, except
from one inland well, due to severe seawater intrusion. The Basin Plan refers to Zones D and
E as a single aquifer (calling them the "Lower Aquifer"); however, the Plan reports that Zone
E was sealed off at a main community supply well (Palisades Well) due to chlo ride levels
above safe limits, and it refers to Zone E as a source of seawater for desalination. It adds that
total dissolved solids (TDS) levels in Zone E exceed the levels of brackish water (1,000 mg/1
to 10,000 mg/1) (Page 24 7). TDS levels are typically roughly double chloride levels. The fact
that chloride levels are not presented for Zone E suggests the Plan is avoiding the issue. As
stated, seawater destroys the Basin when chlorides reach 2500 mgjl, and the Title 22 safe
limit for chlorides in drinking water is 500 mgjl. At the LOCSD meeting, Mr. Miller
acknowledged that the Parties were "not trying to save Zone E." The deep aquifer once
comprised over 1/3rd of the basin's freshwater capacity and contained its purest water,
5,000 to 10,000-year-old "fossil water," unpolluted by nitrates and other contaminants. It
showed no signs of seawater intrusion in the 1970's.
If Zone E is no longer a viable drinking water source, a major concern is whether the Basin
has enough capacity to sustain the current population; another concern is the extent to
which severe intrusion in Zone E will affect Zone D since the Basin Plan describes the
aquitard (clay layer) separating the aquifers as "possibly discontinuous" (Page 64).
Further, the Basin Plan does not estimate how long it will take to raise water levels in Zone D
enough to reverse seawater intrusion, or how much more of the basin will be destroyed by
that time. Currently, three-fourths of the urban water supply is pumped from Zone D, and
the Basin Plan acknowledges pumping levels are not sustainable. It estimates 460 AFY of
pumping must be shifted from ZoneD in the Western Area to ZoneD in the Central Area, and
to the Upper Aquifer to achieve "sustainable" conditions. However, a "sustainable"
condition, as defined in the Basin Plan is a condition in which no active well has a chloride
level above 250 mgjl. Therefore-as acknowledged in the Plan-"sustainable" defines a
condition in which seawater advances much further into the basin. This additional progress
is seen when Figure 27 is compared to Figure 38. Although the Basin Plan provides a map
showing where seawater would stop under "sustainable" conditions, it does not estimate
how long this condition will take to achieve. A 2009 report prepared by Cleath-Harris for
the Parties ("Flow Model Conversion and Urban Area Yield Update" by Spencer Harris of
Cleath-Harris Geologists, Inc.") predicts "sustainable" conditions based on "50 and 500-year
snapshots," but that report assumes much different "sustainable yields" (much lower yields
for Zone D and much higher for Zone C, the Upper Aquifer). Thus, Basin Plan "sustainable
yields" are questionable to begin with. At best, they would not stop seawater intrusion for
several decades. (See 2009 report by Cleath-Harris, Pages 5 & 6, attached and Parts II).
The draft Pian estimates that recommended Infrastructure Program AC will take about three
years to construct and another five years before the first signs of rising water tables are seen
(Pages 106 and 238). It also estimates it will take 15 years for chloride levels to drop, once
the aquifer levels are high enough to reverse intrusion (8 feet above msl) (Page 106). Thus,
if seawater continues to move inland at the 2005-2009 rate (about 1/2 mile every 4-5
years), it could progress another mile into the Basin even before the first signs of rising
water levels (about eight years), and it could travel two miles or more inland before the
contamination of freshwater by seawater shows the first signs of reversing-assuming the
programs are effective. The Western and Central Areas of the Basin extend only about two
miles from where the seawater intrusion front was last measured in Zone D--even with
Broderson Avenue (see Figure 26). Therefore, at the 2005-2009 rate of seawater intrusion,
Zone D could be destroyed by seawater before the Basin Plan predicts intrusion will show
signs of reversal (i.e., in 15 years or so).
The Basin Plan recommends adding a 20% margin of safety to "sustainable" yields to
account for uncertainties (i.e., reducing production to 20% below these yields), and it states
that the margin will push the seawater interface offshore. Undoubtedly the margin increases
the likelihood of reversing seawater intrusion, but the Plan does not estimate when seawater
will be reversed under any scenario-and the margin of safety is not likely enough to
reverse seawater intrusion (see Part II).
Two other facts presented in the Basin Plan show how severe the problem is and how
difficult it will be to reverse. The Basin Plan estimates total freshwater storage capacity of
the Basin at about 205,000 acre feet (AF), 140,000 AF in the Lower Aquifer and 65,000 AF in
the Upper. It says only 40,000 AF are above sea above sea level (can be pumped without
inducing seawater intrusion) almost all in the Upper. It adds that the storage above sea level
provides a sufficient buffer against seawater intrusion during droughts, given annual
community water use under 3,000 AF. However, the 2003 Yates and Williams study
estimates total Basin storage at about 500,000 AF (452,000 AF in the Lower Aquifers and
37,800 AF to 50,400 AF in the Upper Aquifer). Unless one of the studies is way off in its
estimate, the difference could mean that over half of the Basin's freshwater capacity has
been rendered unusable by seawater intrusion.
Also, the Basin Plan reports that the community reduced water use by almost 40% since
about 1988 (Page 140). This is good news because the large reduction has brought
production in the Basin down much closer to a true safe yield. (The safe yield of the Basin
has been overestimate by 700 to 1000 AFY for at least 15 years (3,200 to 3,500 AFY versus
the 2450 AFY per the Basin Plan), and the Basin has been over drafted by over 700 AFY on
average for 34 years. It is bad news because seawater intrusion has continued although
conservation is widely recognized by experts as the most cost-effective and immediate way
to reduce seawater intrusion (since it reduces the pumping causing it and allows water
levels to rise). The fact that rapid seawater intrusion continues with almost a 40% water use
reduction shows how difficult seawater intrusion will be to reverse, and it means there is
much less conservation potential to do it with. Undoubtedly, so much co nservation would
have had a greater effect on seawater intrusion if, at the same time, more pumping had been
shifted away from Western Area in ZoneD, but it remains to be seen if enough conservation
potential still exists to bring up low water tables in Zone D (the large pumping depression
under much of the community) without over pumping Zone C or other parts of the Basin.
One fact is certain- all of these programs must be maximized to optimize flexibility and the
potential for success.
Recommendations:
1. Accurately describe the threat of seawater intrusion to the Basin by explaining the
conditions above.
2. Acknowledge the need for urgent, decisive action so that more of Basin is not destroyed.
3. Present scenarios/programs to bring water tables up in all of Zone D to an average of 8
feet above mean sea level (msl) as soon as possible and project how long each will take to
meet the objective.
4. Stop pumping altogether from Zone E, analyze its potential adverse impacts on Zone D
(from very high salt levels and a discontinuous layer separating the aquifers), and devise
a plan to save Zone E. Present scenarios/programs to bring water tables up in the
aquifer an average of 17 feet above mean sea level (msl) as soon as possible and project
how long each will take to meet the objective.
5. Expand water level and chloride metrics to include wells measuring changes in the
pumping depressions of all production zones (Zones C, D, and E)-and change the
chloride metric to 60 mg/1 (much closer to historic chloride levels than the proposed 100
mgjl, which indicates continued seawater contamination). (The water level metric for
Zone E will have to be near 17 feet above mean sea level.)
6. Implement enhanced conservation and reuse programs that maximize seawater
intrusion benefits by maximizing pumping reductions in the Western and Central Areas
(see recommendations below)-also include an enhanced infrastructure program
(Implement Program D with the recommended Program AC as a first step).
7. Target a reduction in pumping in the Western and Central Areas of the Basin to no more
than 1000 AFY within two years. [Target 0 AFY pumped from Zone D in the Western
Area, 400 AFY pumped from Zone D in the Central Area, 500-600 AFY pumped from the
Upper Aquifer in the Western and Central Areas (with Program AC), and 300-400 AFY
pumped from the Eastern Area (via Program D). This would make total production for
the urban population about 1400 AFY, near the 1450 AFY recommended in the Basin
Plan (Page 6), also maintaining the current production for agriculture at 750 AFY. With
this scenario, total production for the Basin would be about 2150 AFY, about 300 AFY
(12%) under the Basin Plan's "sustainable yield" for current conditions (2450 AFY) and
190 AFY (10%) over the "sustainable yield" with a 20% margin of safety for current
conditions (1960 AFY). This approach applies a 20% margin of safety (as the Basin Plan
recommends) but reduces reliance on the Model by assuming shifts in pumping with
Infrastructure Programs ACD increase Basin yield by about 10%, rather than 20-40%.
The 1000 AFY target within two years for the Western and Central Areas should
maximize the potential to bring up water tables in Zone D, while not adversely impacting
Zone C-thus, maximizing the chance of reversing seawater intrusion as soon as possible.
This scenario does not use all the potential of Program D, leaving 200-300 AFY of
estimated yield as a buffer and to adapt to adverse impacts (e.g., LOWWP impacts). (Also,
see Part 2 below for why these assumptions and the approach are needed.)
II.
The Plan relies too heavily on a Model with substantial uncertainty and a questionable
finding/assumption that moving production in Lower Aquifer Zone D to the Upper
Aquifer and inland will increase basin yield significantly.
A main focus of the Plan is to move more pumping inland in Zone D and to the Upper Aquifer
with infrastructure programs. The Plan estimates Infrastructure Program AC will increase
the yield of the basin to 3000 AFY from 2450 AFY, and it estimates that adding Infrastructure
Programs B and D to Program AC will raise "sustainable yields" to 3500 AFY (Pages 237 &
239). Eugene Yates, however, is clear that shifts in pumping do not increase basin yields
long-term. In a January 2010 review of Basin yields (entitled "Review of Cleath-Harris
Geologists' July 2009 Memorandum 'Flow Model Conversion and Urban Area Yield Update'"),
Mr. Yates states
The proposed management actions to address the saltwater intrusion problem do not
increase basin yield, but shift the location of groundwater extraction. For example,
pairing shallow and deep wells at major pumping locations provides the opportunity
to adjust the proportion of water pumped from the upper and lower aquifers but it
does not increase yield. Furthermore, there are limits to this strategy because of the
uncertainty in the capacity of the upper aquifer to support additional extractions and
the possibility of seawater intrusion occurring in the upper aquifer. (See Yates 1/ 13/
2010 review, Page 4).
In an August 2010 review of the Basin Update (entitled "Review of Los Osos Basin Update
and Current Wastewater Project Description-Revised"), Mr. Yates points out that seawater
intrusion is mainly a problem of basin imbalance ("more water consumed in the basin than
being replenished") and he recommends maximizing indoor-outdoor conservation, storm
water recharge, rainwater harvesting and low impact development recharge to tip the
balance toward more water entering the basin than leaving it (see Yates 6/10/2010 review,
Page 1).
Mr. Yates points out (and the Basin Plan agrees) seawater intrusion cannot be stopped and
reversed until water levels in the a quifers are above sea level. The infrastructure program
recommended in the Basin Pla n (Program AC) involves moving most pumping inland to the
Wimer comments on Draft Basin Plan, 10/2 013, Page 6 of15
Central Area, but maintaining most of the pumping from ZoneD (1260 AFY ZoneD vs. 950
Zone C-Page 237). Water levels in Zone D are already low throughout the Western a nd
Central Areas (Page 64). The assumption that shifting more pumping inland in ZoneD will
increase yields and bring water levels up in the aquifer is not credible-especially when the
recharge regime and structure of the Basin are considered. Virtually all recharge of the
Lower Aquifer in the Western and Central Areas is from the Upper Aquifer, or Lower
Aquifer in the Eastern Area, according to the 2005 Seawater Intrusion Assessment (p. 77).
Also, based on cross sectional maps of the Basi n (e.g., Figure 27, Page 87) ZoneD tapers up
as it nears Los Osos Creek, indicating that proposed wells will tap the aquifer at higher
elevations. Higher elevations of Zone D undoubtedly supply lower elevations. Whereas
additional wells in the Central Area may increase yields incrementally (i.e., allow extraction
of some additional water flowing toward the estuary or creek), most of the groundwater in
the Central Area apparently flows west to lower parts of the Basin. Therefore, additional
inland Zone D wells (e.g., Program C) are not likely to produce a significant net increase in
yield or bring up water levels significantly. It is just as likely to lower water levels a nd pull
seawater furth er into Zone D and/or cause adverse impacts on private wells or sensitive
habitat in the area.
The prediction in the Basin Plan that moving production inland and to the Upper Aquifer
will substantially increased yields is based on the Basin Model, with substantial margins of
error. Based on a peer review of the Model, the Basin Plan says the Model has been found
to be a good bas is for determining yields and the rate of seawater intrusion (Page 77).
However, Mr. Peter Pyle, of Stetson Engineers, chooses his words carefully in his review of
the Model (which is included in the 2010 Basin Update.) According to the Basin Plan, Mr.
Pyle says that the Model is okay to use to "initiate" changes so long as changes are "gradual"
and there are monitoring and contingency plans in place. He also states that the "structure"
of the Model is "sound and able to simulate hydrologic processes in the Basin, particularly
as regards to the ... extent of seawater intrusion in each of the main water bearing units
(Zones C, D, and E)," but he recommend s re finements in the Model and he does not say the
Model is able to accurately predict the extent of seawater intrusion now-and for good
reason. The technical memorandum entitled "Flow Model Conversion and Urban Area Yield
Update" by Spencer Harris of Cleath-Harris Geologists, Inc. (2009)-which introduced the
latest version of the Model and first estimated "sustainable yields" based on the Modelreports that the Model underestimated seawater intrusion progress in Zone E by 1000 to
2000 feet per year (see Cleath-Harris TM "Urban Yield," Page 4, attached). More recent
information in the Basin Plan reveals the inaccuracy was even greater because seawater
intrusion in Zone E had moved even faster. The Basin Plan states "...a back calculation of
historical water quality data shows that th e intrusion front in Zone E had a lready reach ed
the Palisades Well by 2005," which required changing the " ... historical rate of seawater
intrusion in Zone E between 1977 and 2005 ".. .from 54 feet per year to approximately 180
feet per year" (Page 85).
The Basin Plan also fails to mention that Mr. Pyle wrote his review without the benefit of the
2010 Basin Update (and the Cleath-Harris technical memorandum contai ned in the Update),
which first revealed that seawater intrusion had accelerated by at least 10 times in Zone D
between 2005 and 2009. In other words, in 2009 the Model was at least a 1000% off in its
simulation of the rate of seawater intrusion, showing "an average velocity of 60 feet per
year" when it was closer to 700 feet per year (Page 4).
The Basin Plan acknowledges there is a good deal of uncertainty in the Model and it
mentions some of the sources. However, it leaves out some of the sources Mr. Yates lists in
his 2010 review of the Cleath-Harris 2009 technical memorandum. Eugene Yates, one of the
creators of the Model, cites one source that could result in an error of 40% in yield estimates
(see Yate's 1/13/10 review, Page 3). He expresses particular doubts about the Model's
ability to predict yields with the combined impacts of the LOWWP and a lot more pumping
from the Upper Aquifer (a condition unlike any in the basin's history). He also cites the
possible use of potable water for habitat restoration to mitigate LOWWP impacts on
wetlands as a source of error, and he points out that Broderson leach fields will not restore
groundwater flows to some habitat along Morro Bay Estuary (see Yate's 1/13/10 review,
Page 4). The LOWWP is likely to stop at least 300 AFY of groundwater flows to Morro Bay
Estuary and sensitive habitat (the difference between eliminated septic system flows, 780
AFY, and the groundwater Broderson and Bayridge leach fields is supposed to replace, 480
AFY). There is no LOWWP project document that makes it clear how this water will be
replaced if necessary to avoid adverse impacts on habitat.
To account for uncertainties in the Model, the Basin Plan recommends adding a 20% margin
of safety to yields (targeting yields of 80% of "sustainable yields" as determined by the
Model), and it states the margin will also result in reversing seawater intrusion. However,
the Plan does not say how it arrives at the 20% margin-and 20% is not likely enough to
account for uncertainties-let alone reversing seawater intrusion.
One fact supporting the need for a larger margin of safety and less reliance on the Model is
that Cleath-Harris has had to revise down basin yield estimates for current conditions from
about 3,500 AFY in 2000 to 3,200 AFY in 2009, down to 2,450 AFY in 2012 (with the Basin
Plan). (Note that 2,450 AFY is a "sustainable yield," which allows seawater intrusion to
advance substantially further). With the 20% margin applied, under current conditions a
yield of 1960 AFY would be required to reverse seawater intrusion per the Basin Plan. As
the Plan points out, the "sustainable yield" has been exceeded since 1979 (34 years) by an
average of 700 AFY or 30%, and it has been over drafted by 1100 AFY if the safer yield
estimate of 80% of sustainable yield is applied. The total overdraft is 23,800 AF to 37,400
AF or 10 to 15 years of water use in the Basin as "sustainable yield" levels. This longstanding overdraft, which resulted in much of the Basin being destroyed- is due to modeling
error. More fundamentally, it is due to an over reliance on the Model and a tendency for
decision-makers to support overly-optimistic projections of Basin yield (i.e., to err on the
side of maximizing production rather than sustaining the Basin).
In 2009, Cleath-Harris drastically changed the yield estimates for the Upper and Lower
Aquifers. Estimates for the Lower Aquifer in the Western and Central Areas of the Basin
were cut in half to between 600 and 725 AFY from 1300 AFY, and "safe" yield for the Upper
Aquifer was increased from 1150 AFY to about 1450 AFY, indicating that the Lower Aquifer
yields had been overestimated by 600-700 AFY and Upper Aquifer yields underest imated by
300 AFY for many years. The Cleath-Harris safe yield estimates for the Upper and Lower
Aquifers are taken from the 2007 Resource Capacity Study, Page 9.
Finally, the "sustainable yields" based on the latest version of the Model, which Cleath-Harris
presents in 2009 in the "Flow Model Conversion and Urban Area Yield Update," are different
from the yields Cleath-Harris presents in the Basin Plan based on the same version of the
Model. The 2009 memo estimates "sustainable yields" for water purveyors from the Lower
Aquifer (with the LOWWP) at 725 AFY and Upper Aquifer yields 1325 AFY (see ISJ TM
"Urban Yield," p. 8). The Basin Plan estimates "sustainable yields" with the LOWWP at 1160
AFY for the Lower Aquifer and 580 AFY for the Upper Aquifer (Page 226). Th is is 435 AFY
(or 60%) more than the earlier Cleath-Harris estimates for the Lower Aquifer.
According to the Basin Plan, all pumping options (i.e., Infrastructure Programs A, B, C, & D)
will produce greater "sustainable yields" fro m the Lower Aquifer than the 2009 CleathHarris technical memorandum estimates-even though the 2009 memorandum also
assumes there will be changes in pumping locations (see ISJ Urban Yield, p. 5 and Basin Plan,
pp. 226-233).
If the Model, including the latest version by Cleath-Harris, cannot consistently and accurately
predict the yields of the aquifers, there is no reason to believe it can predict variations in
yields (including much higher yields) when pumping is shifted to specific locations within
the aquifers.
As explained in the 2009 Cleath-Harris technical memorandum, "sustainable yield s" are
bas ically theoretical conditions that would develop 50 to 500 years out, assuming the Model
is exactly accurate and past conditions match future conditions perfectly (i.e., th ere are no
droughts, no changes in weather patterns, and no LOWWP). The Basin Plan warns of
potential harm to the Basin from not monitoring private wells and applying inaccurate water
use estimates in the Model, and it points out that the error might not be known for 15 years
or more, when it is too late to undo the damage. The same observation applies to modeling
errors.
Because there is no room for error with the Los Osos Valley Water Basin, sustainable yield
estimates and production targets should be substantially lower than the 80% of current
"sustainable yields," as proposed in the Basin Plan. Also, Infrastructure Programs ACD
should be put in place to buy time, optimize safe production, and allow adaptive
management (flexibility in where production occurs) to maximize benefits to the Basin.
Reco mmendations:
1. Add a 30% margin of safety to current "sustainable yields" to arrive at truer sustainable
yields (and/or) recalibrate the Model to calculated safe yields, such that no production
w ell has a chloride level exceeding the historical chloride level of 60 mg/l.
2. Apply the revised definition of "sustainable yield" (from #1 above) and "sustain able"
Basin conditions" throughout the Basin Plan. Eliminate all references to "sustainable
yields" and "a sustainable Basin," which use the "no more than 250 mg/1 of chlorides"
criterion.
3. Limit yield estimates for the Basin to four: one each for the Upper a nd Lower Aquifers in
the Western and Central Areas of the Basin (west of Los Osos Creek) and one each for
Upper and Lower Aquifers in the Eastern Area (east of the Los Osos Creek).
4. Implementation Infrastructure Programs ACD immediately and assume no more than a
10% increase in yield from the Western a nd Central Areas with the.
5. Rely less on the Model and more on basic principles: 1) that the water levels in Zones D
and E must be brought up to above sea level as soon as possible, and 2) this requires
tipping the balance towards substantially more recharge than extraction with a large
margin of safety. (The larger the margin of safety, the less of the Basin is lost and the
more likely it is to be sustainable) .
6. Upgrade the Model and continue to refine it based on actual well tests.
Wimer comments on Draft Basin Pl an, 10/2013, Page 9 of 15
fSee Part I for further sustainable yield recommendations.}
III.
The Plan does not commit the County and purveyors to take urgent action, or any
action, and a Basin-wide ordinance is needed. Although the Basin Plan recommends a set
of programs for the Parties to implement, the Basin Plan does not commit the Parties to any
specific action, especially urgent action.
The Plan is basically a set of goals with recommendations reflecting the same general
recommendations presented in every draft management plan and agency review of the Basin
for 40 years-i.e., relocating wells and intensive conservation. The Basin Plan states in
several places that the Parties are deciding what actions to take and haven't agreed on any.
It also recommends that funding for actions comes from a general assessment on the
Community of Los Osos, but the community is likely to reject an assessment due to large
assessments for the LOWWP, which are causing steep increases in property taxes.
The Parties have been very slow to implement well relocations and aggressive conservation
in the past, and have taken five years just to negotiate the draft Basin Plan although it was
their stated goal in the ISJ to have the Basin Plan fully implemented within 12 months of the
signing of the agreement in August 2008 (see IS], Page 6). The Parties were also supposed to
negotiate and implement an intertie agreement within four months of signing the agreement
(ISL Page 9), but this is still not done. In 2010 the Parties commissioned a study, which
showed a community nitrate facility would be cost effective, but it was not implemented.
The fact that most of the production in the Basin is still from Zone D wells in the Western
Area and the Parties have not completed the above actions is a good indicator of the Parties'
level of commitment to stopping seawater intrusion and it bodes poorly for the future. In the
2010 Basin Update, the Parties state the need for "quick and decisive action," but the Basin
Plan doesn't restate or convey that need-and the level of action taken so far does not reflect
the level of commitment needed to address the severe problem.
While the Plan sets an "Immediate Goal" of halting and reversing seawater intrusion, it does
not identify specific, aggressive objectives and timeframes. It further does not maximize
conservation with a strong outdoor component, nor does it propose an aggressive recycled
water use program. The law and the ISJ agreement under which the Parties are developing
the Basin Plan, allow the County to implement a basin-wide ordinance to implement the
Plan, which could set time-specific objectives for stopping seawater intrusion, but the Basin
Plan does not mention the option. Instead, it indicates that a Water Master under the
Control of the Parties will be appointed to oversee implementation.
The Basin Plan does recommend that the County implements an ordinance requiring private
well owners to report well production, but it rejects an ordinance requiring the same
property owners to conserve water. What is needed is a County basin-wide water
management ordinance, enacted within one year that implements these measures and
others within two years, in order to reverse seawater intrusion as soon as possible (5-7
years).
Recommendations:
1. Support/require implementation of a County basin-wide water management ordinance
to implement maximized Basin Plan measures/programs within one year.
2. Support/require the Basin-wide ordinance to set a time-specific objective to stop
seawater intrusion by fully implementing maximized conservation, reuse, and
infrastructure programs within two years and raising water tables in Zones D and E to
above sea level within 10 years, with targeted benchmarks (e.g., rises in water levels as
measured in metric wells). The ordinance would also include adequate
incentives/enforcement mechanisms to achieve the objectives.
3. Apply for funding from the State Water Board and other agencies to implement
programs.
IV.
The Basin Plan ignores established facts regarding the structure of the basin.
Since the 1980s, Basin studies have recognized that the Basin east of Los Osos Creek (the
Eastern Area) is a separate compartment, historically referred to as the Creek Compartment,
which functions semi-independently of the part of the Basin west of Los Osos Creek (the
Urban Compartment). As a result, safe yields have traditionally been calculated separately.
The Creek Compartment (or the Eastern Area in the Basin Plan) contributes some
groundwater flows to the Urban Compartment (Western and Central Areas in the Basin
Plan), but a reduction in pumping in the Creek Compartment (Eastern Area) would not be
noticed as an increase in water levels in the Urban Compartment (Western and Central
Areas) for several decades if at all. This is why the LOWWP EIR estimates that the seawater
intrusion mitigation potential of recycled water use in the Creek Compartment is only 1j5th
or 20% of the Urban Compartment's mitigation value (a 0.1 mitigation factor versus a 0.55
factor). Furthermore, the 1j5th or 20% would be a long-delayed benefit with much higher
levels of uncertainty than mitigation in Western and Central Areas, where recycled water
reduces pumping causing seawater intrusion and immediately mitigates seawater intrusion.
The Basin Plan recognizes that pumping from different locations in the Basin has greater or
lesser effects on seawater intrusion, but it fails to recognize that conservation and recycled
water use in the Eastern Area will have much less benefit on seawater intrusion than the
same programs in the Western and Central Areas. The "Solutions" section of the Basin Plan,
estimates the degree to which various programs achieve target yields, chloride levels, and
water levels as shown by "metrics," but the metrics and calculations do not factor what parts
of the Basin the programs affect. By failing to distinguish the effects of programs on the
Eastern Area versus the Western and Central Areas, the Basin Plan exaggerates the benefits
of conservation and reuse programs in the Eastern Area on seawater intrusion, and it
ignores the potential for stopping seawater intrusion and managing the Basin sustainably by
redistributing water from the Eastern to Western and Central Areas of the Basin and viceversa. Recognizing that the Basin has two relatively distinct sub-basins is necessary for
maximizing resources and opportunities to achieve a sustainable Basin.
Recommendation:
1. Recognize and build into programs and planning the fact that the Basin has two semidiscrete compartments, one of which is severely impacted by seawater intrusion with
low water tables and the other of which is apparently healthy with excess capacity that
allows additional pumping.
2. Recognize and build into planning the fact that reduced pumping must occur in the
Western and Central Areas to mitigate seawater intrusion significantly.
V.
The Plan overstates the benefits of water recycling programs and ignores the need
and potential for a much stronger program.
The Plan indicates the Urban Water Reinvestment Program (essentially the LOWWP
recycling program) will increase basin yield over current conditions (Pages 279 & 281). The
Plan, therefore, assumes that the combination of recycled water discharged in Broderson
and Bayridge Estates leach fields (up to 480 AFY), the water recycled in the Western and
Central Areas of the Basin (about 100 AFY), and the water recycled in the agricultural area
east of Los Osos Creek (about 200 AFY); will provide greater recharge benefits than septic
systems (i.e., current conditions). However, this assumption is faulty as shown by a simple
calculation of Basin balance, keeping the Basin's structure in mind. The LOWWP removes
780 AFY of groundwater from the Western and Central Areas of the Basin by removing
septic systems, and it returns it only about 580 AFY to the areas. The Basin Plan claims the
program increases irrigation return flows; however, since it does not increase irrigation, it
does not increase return flows (Page 281). The Model may credit Broderson leach fields
with more efficient recharge of the aquifer, which could explain the additional mitigation
benefit; however, the Model is not time sensitive. Broderson leach fields will take more than
15 years to restore flows and Basin equilibrium-if it works as the EIR predicts, which is frar
from certain-so the measure will not effectively offset seawater intrusion for that many
years. In fact, the discharging water in the leach fields results in a significant deficit in water
balance and mitigation (i.e., adverse potential impact on water levels) in the near term. This
adverse impact is compounded by the dewatering program going on now, which removes
recharge from Upper Aquifer.
The Basin Plan also fails to recognize that water recycled in the agricultural areas (Eastern
Area) does not offset pumping significantly in the Western and Central Areas (as described
in Part IV above). Pumping must be reduced in the Basin west of Los Osos Creek to stop
seawater intrusion. The Basin Plan treats the Basin as a single unconfined aquifer when
calculating the benefits of the recycled water program, although the LOWWP EIR and all
Basin studies since the 1980's make it clear that a reduction is potable water use in the
Eastern Area (e.g., via recycling) will have only minor benefits on seawater intrusion, if any
at all.
Without clear justification, the Basin Plan considers Infrastructure Program D (additional
wells in the Eastern Area) only as a source of water to support further development in the
community. It fails to consider the program as a source to help stop seawater intrusion and
mitigate the impacts of the LOWWP. Program D can and should be implemented
immediately along with Program AC for three reasons: 1) to reduce pumping from the
Western and Central Areas to stop seawater intrusion as soon as possible, 2) to offset the
removal of recycled water from the Western and Central areas, and 3) to provide a water
source for adaptive mitigation measures for seawater intrusion and habitat impacts as
needed, e.g., to reduce where and when water is pumped to respond to signs of seawater
intrusion or habitat destruction from the LOWWP and Basin Plan programs). An important
benefit of program D is that it effectively provides an agricultural exchange program-as
recommended by several authorities, including Eugene Yates and the Monterey Bay
Watershed Institute. Basically, Program D optimizes Basin management by maximizing
sources of water.
Finally, the recycled water program can and should be made stronger with the installation of
more purple pipe, especially to parts of the community with larger lots now drawing water
from the Central and Western Areas of the Basin. These properties use water at rates 3 to 4
times that of water users in other parts of the urban area, with most of it outdoors. Use of
recycled water for outdoor irrigation on large lots (about 200 properties now using an
average of about 1 AFY per lot) could reduce potable water use by more than Yz AFY per lot
per year (more than 100 AFY).
Recommendations:
1. Implement Program D with Program AC and use the water to offset pumping in
seawater-impacted areas, to (effectively) implement an agricultural exchange program
that offsets recycled water applied in the Eastern Area, and to adapt/respond to potential
impacts from major changes in Basin hydrology in the next few years.
2. Install additional purple pipe, especially to parts of the community with large lots
drawing water from the Central and Western Areas of the Basin.
3. Do not assume the Urban Water Reinvestment Program increases Basin yield; instead,
focus on maximizing the program to ensure the water extracted in the Western and
Central Areas and entering the wastewater system is offset either with recycled water or
freshwater from the Eastern Area that replaces recycled water delivered to that part of
the Basin--i.e., be sure be sure the Recycling Program achieves a 1:1 offset.
VI.
The Plan overstates the benefits of the current conservation program and ignores the
potential and the need for a much stronger program.
The Basin Plan stresses the need for a "state-of-the-art" water-use efficiency (conservation)
program to stop seawater intrusion, and sets the goal of achieving such a program (Pages
139 & 147). However, the Basin Plan's proposed Urban Water Use Efficiency Program
(UWUEP) sets conservation targets too low (sets water use targets too high) and overstates
the benefits of the proposed program. It also rejects effective measures, including leak
repair, turf replacement, low-water use la ndscaping, and rainwater harvesting/recharge
measures such as rain gardens. In general, it backs away from implementing a state-of-theart program even though the public would most likely support it and such program is vital to
stopping seawater intrusion.
The Basin Plan proposes to extend the LOWWP conservation program Basin-wide (adding a
few outdoor measures) to create the proposed "Urban Water Use Efficiency Program." It also
recommends that the County administers the entire indoor-outdoor program until 2018, at
which time Purveyors will take it over. The Plan further recommends that LOWWP
conservation funding ($5 million) is increased to $5.5 million, and shifted from LOWWP
funding to a Basin-wide assessment.
The Basin Plan program, like the LOWWP conservation program, does not maximize
conservation, in large part because both programs rely on a plan the Parties commissioned
by Maddaus Water Management (MWM), which does not maximize conservation. The MWM
Plan sets th e water use target too high (SO gpcd indoor by 2015), recommends against
incorporating many effective measures, and extends over too long a time period (until
2035). The MWM plan also exaggerates potential water use reduction in at least two ways:
1) by overstating baseline water use using out-of-date data provided by the Parties, and 2)
by overstating indoor water use versus outdoor use (which results in exaggerated benefits
for the LOWWP indoor program). (See "Los Osos water use and potential conservation
estimates (2012)-draft" by K. Wimer attached.)
The Los Osos Sustainability Group (LOSG) commissioned a review of the MWM plan by Peter
Mayer of Aquacraft located in Boulder Colorado. Aquacraft and Mr. Mayer have done several
conservation end-use studies for the USEPA, including a comprehensive study of California
residential water use. Mr. Mayer concludes that that the MWM plan does not reduce water
use as much as possible, and thus does not maximize seawater intrusion mitigation. Based
on a California-wide survey of water use by Aquacraft for the USEPA, he states that indoor
water use can be reduced to 42 gallons per capita per day (gpcd) with efficient appliances
and fixtures on the market, in addition to leak repair. He adds that a 42 gpcd indoor target
can be easily achieved using the $5 million the County is required to spend to "initiate" the
LOWWP program (i.e., per Coastal Development Permit, Special Condition 5b).
The Basin Plan estimates the proposed program will reduce water use about 300 AFY by
2035. However, the program overestimates the benefits of the program by at least 100 AFY;
whereas a good comprehensive indoor-outdoor program could reduce water use by about
470 AFY (see "Los Osos water use and potential conservation estimates" attached).
Recommendations:
1. Implement a comprehensive indoor-outdoor program with a full range of measures,
including leak repair, low-water use landscaping, rainwater harvesting/recharge, turf
replacement, and grey water reuse.
2. Set the target for indoor residential use at 42 gpcd, with the indoor-outdoor target at 63
to 69 gpcd.
3. Set the baseline target at 80 gpcd Basin wide (Baseline use is calculated by dividing total
use, including residential and CII use, by the total population.)
4. Fund the measures with grants and, if grants are not available, with rate increases so
they can be implemented in the near future. (Later, shift costs to a Basin-wide
assessment.)
5. Apply tiered rates and be sure rate increases reflect the full avoided costs for
supplemental water.
6. Purveyors and the County share in the funding and administration of the program
beginning this year, so that rate increases, if necessary, can cover some of the costs early
on.
7. Enact conservation targets, measures, and incentives with a Basin-wide management
ordinance that has the specific objective of reversing seawater intrusion (per
recommendations above).
8. Implement tiered rates based on individual water budgets, as recommended by Peter
Mayer, in the near future to avoid undue impacts on larger families.
9. Integrate the septic system decommissioningjrepurposing program with the Basin-wide
indoor-outdoor conservation program for efficiency and cost-effectiveness (and consider
having SLO Greenbuild extend its current role to help implement all programs).
VII.
The Plan fails to account for the potential impacts of the LOWWP
The Basin Plan fails to acknowledge or account for potential adverse impacts from the
LOWWP on the Upper and Lower Aquifers. Eugene Yates points out that project impacts are
likely to be greatest on the Upper Aquifer, due the combined impacts of the elimination of
septic recharge and increased pumping from the Upper Aquifer. He did not factor the
adverse impacts from dewatering or the continuing drought. As mentioned, the main
mitigation measure to avoid/minimize groundwater impacts, Broderson leach fields, will not
restore water levels for 15 years or more after elimination of septic recharge, according to
the Monterey Bay Watershed Institute. Although the Basin Plan acknowledges some
"uncertainty" associated with the LOWWP, it does not mention impacts or propose a
contingency plan. Further, it does not assume the LOWWP conservation and reuse programs
will be needed to offset the impacts of the project as intended, but instead it assumes the
programs will contribute to stopping seawater intrusion. In fact, the impacts of the LOWWP
on the Upper Aquifer may cause seawater intrusion in that aquifer, and preclude shifting
more pumping to the Upper Aquifer resulting in further destruction of the Lower Aquifer.
The LOWWP is a main reason mitigation programs must be maximized as soon as possible.
If the Basin (e.g., Upper Aquifer) does not survive in the short term, the potential long-term
benefits of the LOWWP (a reduction in nitrates in the Upper Aquifer) will not be realized.
Recommendation:
1. Acknowledge LOWWP impacts and build adaptive measures into the Basin Plan and
Basin-wide ordinance that address impacts (also see recommendations in Parts I and II.)
2. Support stronger mitigation programs for the LOWWP as part of the COP, WDR, and
other permitting requirements.
Los Osos water use and potential conservation estimates (2012)
Prepared by Keith Wimer 1012013
Current water use
I.
Population
• "Urban" (total population)- 14,600 (per Basin Plan)
• Purveyor/USL (purveyor service area/urban services line)- 14,100 (Assumes 500 residents use private wells
based on Basin Plan)
• PZ (wastewater service area/prohibition zone)-12, 450 (per a Planning Commission memo, July 23, 2009)
2.
Total water production (2012)
•
U rban- 1720 AFY (total purveyor production of 1520 AFY in 2012, plus 200 AFY per Basin Plan, Page 38)
• Purveyor/USL-1520 AFY (total purveyor production 20 12, per Basin Plan--Page 35)
• PZ-1329 AFY (87.3% of Purveyor/USL based on the population ratio, i.e., 12,450 / 14, I00 minus 1%)
{Note: The 1% is subtracted as a conservative estimate of the lower water use within the PZ than outside, but
within the Purveyor/USL area (12% of the properties, and about 1650 people). Properties outside the PZ tend to be
larger and more outdoor water use is likely.}
3.
Baseline per capita water use (includes Cll, residential, and unaccounted fo r water)
• Urba n--105 gpcd (1720 AFY/14,600 population)
(Note: The Basin Plan estimates 120 gpcd based on a 5-year water use average ami 135 gpcd for the 2006-2008
average. These estimates overstate current use and the potential benefits of the LOWWP and Basin Plan
programs-also see "Variations from Basin Plan data/assumptions" below.)
• Purveyor/USL-96 gpcd (1520 AFY/14,100 population)
• PZ- 95 gpcd (1329 AFY/12,450 population)
(Note: The goal of the Basin Plan is to reduce water use to 94 gpcd, so the goal is very close to being achieved, or
has a/really been achieved, within the USL and PZ. Also, see note for PZ in #2.)
4.
Current per cap residential use indoor and outdoor by group/area (assumes residential use is 80.8% per MWM Plan,
Page 23)
• Urban-85 gpcd (1720 AFY x .808 I 14,600 population)
• P urveyor/USL-78 gpcd ( 1520 AFY x .808 I 14,100 population)
• PZ- 78 gpcd (1342 AFYx .808 I 12,450 population) (see note for PZ in #2.)
(Note: The above shows opportunity for reduction among all groups, but significantly greater potential for
reduction outside the PZ-see "Discussiou!Conclusions. '')
Current per cap residential use indoor vs. outdoor (assumes indoor use is 66% of total use--see note in "Sources of
data/assumptions" below)
• Urba n-56/29 gpcd
• Purveyor/USL-51/27 gpcd
• PZ-51/27 gpcd
(Note: This indicates tlte LOWWP Plan goal of 50 gpcll indoor use within the PZ was very nearly achieved in
2012 before tlte program went into effect- also see note for PZ in #2)
5.
Future water use with conservation--potential reductions
6.
Potential reduction per capita from •·esidential indoor retrofits (including washers) and leak repair (sets 42 gpcd as
achievable target per Mayer Review, Pages 5 & 6, and assumes outdoor use remains at 27 gpcd on average--no
reduction for further outdoor conservation, i.e., more than was occurring in 2012.)
(Note: The County Plan for the PZ does not include leak repair and it is not on track to replace enough washers to
result in a significant reduction from the measure-i.e., 15 washer replacements since January toward a five-year
target of 1665 replacements. )
PER CAPITA USE WITH LEAK REPAIR AND INDOOR RETROFITS (INCLUDING WASHERS)
• Total-69 gpcd (indoor and outdoor combined)
• lndoor-42 gpcd (based on Mayer Review and end use studies, e.g., Mayer 2003)
• Outdoor-27 gpcd
Potential Conservation Estimates-K. Wimer 1 of 3
..
'
POTENTIAL REDUCTION
Urban 150 AFY [(56 gpcd - 42 gpcd x 500 population) + (5 1 gpcd - 42 gpcd x 14,100 population)]
• Purveyor/USL-142AFY (51 gpcd - 42gpcd x 14,100population)
• PZ-136 AFY (51 gpcd - 42 gpcd x 13,450 population)
{Note: Another approxim(ltely 60 AFY of reduction will occur if C/1 measures achieve a 20% reduction (1520
AFY x .2 x .2/.. "Urban" estimates are not included here because the 200 "dditional properties on private wells,
500 additional people, likely have a very higlt ratio of indoor to outdoor water use relative to other
properties/people in the Urban group since all of the properties are over one acre-see Note # 7 and
"Discussion/Conclusions."/
7.
Potential additional reduction from outdoor conservation (assumes the indoor reductions shown in #6 and average
outdoor use is one-half of 42 gpcd or 33% of total use. ~This assumes for outdoor use is still relatively conservati ve
with a good outdoor program that includes grey water use and rainwater harvesting because these two strategies reduce
water pumped and delivered to a home without reducing actual water use.]
PE R CAPITA USE WITH OUTDOOR MEASURES, INDOOR RETROFITS, AND LEAK REPAIR
• Total- 63 gpcd (indoor and outdoor combined- see below)
• lndoor-42 gpcd (per Mayer Review--see #6)\
• Outdoor-21 gpcd (one-half of 42 gpcd, or 33% of total use)
POTENTIAL REDUCTION
• Urban- 220 AFY
(Note: This calculation includes a 125 AFY reduction for homes outside the Purveyor/USL, added to the 95 A FY
potential reduction within the Purveyor/USL- see "Discussion/Conclusions. '')
• Purveyor/USL-95 AFY (69 gpcd- 63 gpcd x 14,100 population)
• PZ- 90 AFY (69 gpcd - 63 gpcd x 13,450 population)
8. Total potential future reductions from residential conservation• Urban--407 AFY [(142 AFY + 45 AFY + 125 AFY + 95 AFY- assumes indoor use of 500 people on private wells
•
•
is redueed from 51 gpcd to 42 gpcd for a 45 AFY reduction and outdoor use for this group is reduced 125 AFY.
These reductions are added to indoor outdoor reductions for the Purveyor/US L group-see #6 & #7)].
Purveyor/USL-237 AFY (142 AFY + 95 AFY-- See #6 & #7)
PZ-202 AFY ( 11 2 AFY + 90 AFY --See #6 & #7)
(Note: Another approximately 60 AFY o[ reduction will occur i[ CII measures achieve a 20% reduction (1520
A FY x .2 x .2- see "Discussion/Conclusion" below.)
Sources of data and assumptions-The water-use data/assumptions here are taken from the fo llowing
documents: the Draft Basin Plan (Basin Plan), the 201 1 Water Demand Analy sis and Water Conservation
Evaluation--Administrative Review Draft by Maddaus Water Management (MWM plan), the Water Conservation
Implementation Plan for the LOWWP prepared by the SLO County Public Works Department, date stamped
6/30/ 12 (County plan), a review of the MWM plan prepared for the Los Osos Sustainability Group by Peter Mayer
of Aquacraft Water Engineering & Management (Mayer Review), and other sources noted.
Based on the draft Basin Plan, this considers all water use among residential pri vate well-users (non-farming well
use outside the purveyor service area) as "urban" use, and assumes 200 properties with private wells, each using
about one acre foot per year (AFY) for a total of 200 AFY. This a lso ass umes the number of residents on these
200 properties is consistent with the area average of2.5 peopl e per residence or 500 people total.
Variations from Basin Plan data/assumptions-This uses 20 12 water use figures (the most recent
data provided in the Basin Plan) as baseline use, not the average of the most recent 5-years as used in the Basin
Plan. The reason for this is that water use in the community has been steadi ly dropping for eight years or more, and
the drop is most likely primarily due to tiered rate structures, more efficient fixtures, and/or greater community
awareness of seawater intrusion. These influences will not change, so use will not likely increase, especially with
the County (LOWWP) plan underway. Based on several sources, including the Mayer Review (which points out
that the M WM Plan most likely overstates the percentage of indoor to outdoor residential use)- this assumes
outdoor use is one-ha lf indoor use, which is assumed to be 66% of total residential use. Indoor use of 66% is a
re lati vely conservative estimate because some sources, e.g., Waste Not Want Not, a landmark study by the Pacific
Potential Conservation Estimates-K. Wimer 2 of 3
•
Institute, estimates indoor use in coastal areas at about 60%, and the 2000 Maddaus conservation plan for Los
Osos estimates indoor use at 54% (see Mayer Review, Page 3). The above estimates further assume--per the
Mayer review and a recent Aquacraft end-use study for California- that indoor use can easily be reduced to 42
gpcd with high-efficiency retrofits, including washers and leak repair (Mayer Review, Pages 5 & 6).
Method- "B asel ine" per capita use is calculated by dividing the total use of a water user group/area by the
total population of the group/area. (Baseline per capita use includes CII water use.) "Residential" per capita use is
calculated by multiplying group/area water use by 80.8% (the percentage of residential to total use per the MWM
Plan--Page 2 1), then dividing by the estimated population for that group/area. Like the Basin Plan, these estimates
include 75 AFY of residential private well use outside of the USL/purveyor area, which the MWM Plan does not
include. Because C ll use is not part of that private well use, this overestimates residential use sl ightly by apply ing
the 80.8% factor to all urban use to calculate res idential use. (This also assumes the MWM Plan estimates the
percentage of Cll use accurately although it overstates baseline water use.)
Discussion/Conclusions-
These estimates indicate that about 470 AFY (467 AFY) of additional water
use reduction is possible (among a ll urban water users, including CII users) with a good indoor-outdoor
co nservation program. About 270 AFY is possible within the PZ and about 200 AFY outside the PZ. These
estimates add the assumed 60 AFY of reduction for CII to the total indoor-outdoor residential esti mated
reductions-see #8 above.
The Bas in Plan estimates a reduction of about 300 AFY from the Urban Water Use Efficiency Program (which
extends the LOWWP program to urban users outside the PZ). However, this overstates the benefits of the
program, especially since the reductions must be with in a few years to address the urgent seawater intrusion
problem. As mention, the MWM plan and Bas in Plan overstate baseline use to arrive overstated estimates, and
they rely on natural conservation over the next 20 years, until2035 (i.e., normal replacement of fixtures/appliances
with more efficient ones as they reach the end of their life spans). The above estimates shows that achieving a 300
AFY reduction within the Purveyor/USL area and a 400 AFY reduction among a ll Urban users req uires a much
more aggress ive program that includes leak repair, I 00% washer replacement, and a more comprehensive outdoor
program. The Basin Plan recommends adding on ly three outdoor meas ures to the current LOWWP indoor
program for Basin-wide expans ion (rain sensor re bates, limited outdoor audits, and education). The LOWWP
washer program targets replacing 1665 washers (about one-third of the washers in the PZ) at a rate of 333 washers
per year for five years. Since January of 2012 (the beginning of the program) only about 15 people have taken
advantage of the $150 rebate and the incentive is clearly ineffecti ve (with washers costing about $700 and washer
replacement not required for hook up to the wastewater project). A conservative estimate is that two-thirds of the
washers in the community could be upgraded for a much greater use reduction.
These estimates indicate that the LOWWP conservation program is likely to produce about a 100 AFY red uction
reduction is use (70 AFY residential and 30 AFY CII). To achieve the 136 AFY reduction in indoor use within the
PZ, shown above, the Basin Plan would have to target 42 gpcd (not 50 gpcd), replace al l washers, and include leak
repair. End use studies show the reduction in indoor water use from leak repair and efficient washers is equi valent
to the reduction from toilet, faucet aerator, and showerhead replacement, which effective ly compri se the current
LOWWP program. If the three outdoor programs recommended in in the Basin Plan are added to the LOWWP
program--and the program per the Basin Plan is extended Basin wide-it may reduce water use another 50 AFY in
the next 5-8 years-half of the claimed 300 AFY. On the other hand, a 470 AFY reduction is possible w ith a more
aggressive and comprehensive indoor-outdoor program. Again, outdoor reduction estimates above are conservative
if a strong o utdoor programs than includes grey water use and rainwater harvesting is impleme nted. Also, stronger
recycling program than recommended in the Basin P la n could reduce potable water use in seawater impacted areas
future.
Potential Conservation Estimates- K. Wimer 3 of 3
Los Osos water use and potential conservation estimates (2012)
Prepared by Keith Wimer 1012013
(Changes to 912013 draft highlighted)
Current water use
I.
Population
• "Urban" (total population)- 14,600 (per Basin Plan)
• Purveyor/USL (purveyor service area/urban services Iine)-14,100 (Assumes 500 residents use private wells
based on Basin Plan)
• PZ (wastewater service area/prohibition zone)- 12, 450 (per a Planning Commission memo, July 23, 2009)
2.
Total water production (2012)
Urban- 1720 AFY (total purveyor production of 1520 AFY in 20 12, plus 200 AFY per Basin Plan, Page 38)
•
Purveyor/USL-1520 AFY (total purveyor production 2012, per Basin Plan--Page 35)
•
• PZ- 1329 AFY (87.3% ofPurveyoriUSL based on the population ratio, i.e., 12,450 114, I00 minus I%)
{Note: The 1% is subtracted as a conservative estimate of the lower water use within the PZ than outside, but
within the Purveyor/USL area (12% of the properties, and about 1650 people). Properties outside the PZ tend to be
larger and more outdoor water use is likely.)
3.
Baseline per capita water use (includes Cit, residential, and unaccounted for water)
•
Urban--lOS gpcd (1720 AFYI14,600 population)
(Note: The Basin Plan estimates I 20 gpcd based on a 5-year water use average and 135 gpcd for the 2006-2008
average. These estimates overstate current use and the potential benefits of the LOWWP and Basin Plan
programs-a/so see "Variations from Basin Plan data/assumptions" below.)
• PurveyoriUSL-96 gpcd ( 1520 AFYI I4,100 population)
• PZ-95 gpcd (1329 AFYI12,450 population)
(Note: The goal of the Basin Plan is to reduce water use to 94 gpcd, so the goal is very close to being achieved, or
has already been achieved, within the USL and PZ. Also, see note for PZ in #2.)
4.
C urrent per cap residential use indoor and outdoor by group/area (assumes res idential use is 80.8% per MWM Plan,
Page 23)
•
Urban-85 gpcd (1720 AFY x .808 I 14,600 population)
• Purveyor/USL-78 gpcd ( 1520 AFY x .808 I 14, I 00 population)
• PZ-78 gpcd (1 342 AFY x .808 I 12,450 population) (see note for PZ in #2.)
(Note: The above shows opportunity for reduction among all groups, but significantly greater potential for
reduction outside the PZ-see "Discussion/Conclusions.'?
C un·ent per cap residential use indoor vs. outdoor (assumes indoor use is 66% qf total use- see note in "Sources of
data/assumptions" below)
Urban- 56/29 gpcd
•
• Purveyor/USL-51127 gpcd
• PZ--51/27 gpcd
(Note: This indicates the LOWWP Plan goal of 50 gpcd indoor use within the PZ was very nearly achieved in
2012 before the program went into effect- also see note for PZ in #2)
5.
Future water use with conservation--potential reductions
6.
Potential reduction per capita from residential indoor retrofits (including washers) and leak repair (sets 42 gpcd as
achievable target per Mayer Review, Pages 5 & 6, and assumes outdoor use remains at 27 gpcd on average-no
reduction for further outdoor conservation, i.e., more than was occurring in 20 12.)
(Note: The County Plan for the PZ does not include leak repair and it is not on track to replace enough washers to
result in a significant reduction from the measure- i.e., 15 washer replacements since January toward a five-year
target of 1665 replacements.)
PER CAPITA USE WITH LEAK REPAIR AND INDOOR RETROFITS (INCLUDING WASHERS)
• Total- 69 gpcd (indoor and outdoor combined)
lndoor-42 gpcd (based on Mayer Review and end use studies, e.g., Mayer 2003)
•
• Outdoor-27 gpcd
•
~
POTENTIAL REDUCTION
•
Urban 150 AFY [(56 gpcd- 42 gpcd x 500 population) + (51 gpcd- 42 gpcd x 14, 100 population)]
Purveyor/USL-142AFY (51 gpcd - 42gpcdx 14, 100population)
•
• PZ--136 AFY (51 gpcd- 42 gpcd x 13,450 population)
/Note: Another approximately 60 AFY of reduction will occur if CII measures achieve a 20% reduction (1520
AFY x .2 x .2f.. "Urban" estimates are not included here because the 200 additional properties on private wells,
500 additional people, likely have a very high ratio of indoor to outdoor water use relative to other
properties/people in the Urban group since all of the properties are over one acre-see Note #7 and
"Discussion/Conclusions."/
7.
Potential additional reduction from outdoor conservation (assumes the indoor reductions shown in #6 and average
outdoor use is one-half of 42 gpcd or 33% of total use. ~This assumes for outdoor use is still relatively conservative
with a good outdoor program that includes grey water use and rainwater harvesting because these two strategies reduc~
water pumped and delivered to a home without reducing actual water use.]
PER CAPITA USE WITH OUTDOOR MEASURES, INDOOR RETROFITS, AND LEAK REPAIR
• Total-63 gpcd (indoor and outdoor combined-see below)
Indoor-42 gpcd (per Mayer Review--see #6)\
• Outdoor-21 gpcd (one-half of 42 gpcd, or 33% of total use)
POTENTIAL REDUCTION
•
Urban-220 AFY
(Note: This calculation includes a 125 AFY reduction for homes outside the Purveyor/USL, added to the 95 AFY
potential reduction within the Purveyor/USL-see "Discussion/Conclusions.'')
• Purveyor/USL-95 AFY (69 gpcd- 63 gpcd x 14, 100 population)
PZ--90 AFY (69 gpcd - 63 gpcd x 13,450 population)
8. Total potential future reductions from residential conservation•
•
Urban--407 AFY [(142 AFY + 45 AFY + 125 AFY + 95 AFY- assumes indoor use of500 people on private wells
is redueed from 51 gpcd to 42 gpcd for a 45 AFY reduction and outdoor use for this group is reduced 125 AFY.
These reductions are added to indoor outdoor reductions for the Purveyor/USL group-see #6 & #7)] .
Purveyor/USL-237 AFY (142 AFY + 95 AFY -- See #6 & #7)
PZ--202 AFY (1 12 AFY + 90 AFY--See #6 & #7)
(Note: Another approximately 60 AFY of reduction will occur if C/l measures achieve a 20% reduction (1 520
AFY x .2 x .2-see "Discussion/Conclusion" below.)
Sources of data and assumptions-The water-use data/assumptions here are taken from the following
documents: the Draft Basin Plan (Basin Plan), the 2011 Water Demand Analysis and Water Conservation
Evaluation--Administrative Review Draft by Maddaus Water Management (MWM plan), the Water Conservation
Implementation Plan for the LOWWP prepared by the SLO County Public Works Department, date stamped
6/30/12 (County plan), a review of the MWM plan prepared for the Los Osos Sustainability Group by Peter Mayer
of Aquacraft Water Engineering & Management (Mayer Review), and other sources noted.
Based on the draft Basin Plan, this considers all water use among residential private well-users (non-farming well
use outside the purveyor service area) as "urban" use, and assumes 200 properties with private wells, each using
about one acre foot per year (AFY) for a total of 200 AFY. This also assumes the number of residents on these
200 properties is consistent with the area average of 2.5 people per residence or 500 people total.
Variations from Basin Plan data/assumptions-This uses 2012 water use figures (the most recent
data provided in the Basin Plan) as baseline use, not the average of the most recent 5-years as used in the Basin
Plan. The reason for this is that water use in the community has been steadily dropping for eight years or more, and
the drop is most likely primarily due to tiered rate structures, more efficient fixtures, and/or greater community
awareness of seawater intrusion. These influences will not change, so use will not likely increase, especially with
the County (LOWWP) plan underway. Based on several sources, including the Mayer Review (which points out
that the MWM Plan most likely overstates the percentage of indoor to outdoor residential use)-this assumes
outdoor use is one-half indoor use, which is assumed to be 66% of total residential use. Indoor use of 66% is a
relatively conservative estimate because some sources, e.g., Waste Not Want Not, a landmark study by the Pacific
.
1nst:tute, estimates indoor use in coastal areas at about 60%, and the 2000 Maddaus conservation plan for Los
Osos estimates indoor use at 54% (see Mayer Review, Page 3). The above estimates further assume--per the
Mayer rev iew and a recent Aquacraft end-use study for California-that indoor use can easily be reduced to 42
gpcd with high-efficiency retrofits, incl uding washers and leak repair (Mayer Review, Pages 5 & 6).
Method- "Baseline" per capita use is calculated by dividing the total use of a water user group/area by the
total population of the group/area. (Baseline per capita use includes CII water use.) "Residential" per capita use is
calculated by multiplying group/area water use by 80.8% (the percentage of residential to total use per the MWM
Plan--Page 2 1), then dividing by the estimated population for that group/area. Like the Basin Plan, these estimates
incl ude 75 AFY of residential private well use outside of the USL/purveyor area, which the MWM Plan does not
include. Because Cll use is not part of that private well use, this overestimates residential use slightly by applying
the 80.8% factor to all urban use to calculate residenti al use. (This a lso assumes the MWM Plan estimates the
percentage of C U use accurately although it overstates baseline water use.)
Discussion/Conclusions-
These estimates indicate that about 470 AFY (467 AFY) of additional water
use reduction is possible (among all urban water users, including Cll users) w ith a good indoor-outdoor
conservation program. About 270 AFY is possible w ithin the PZ and about 200 AFY outside the PZ. These
estimates add the assumed 60 AFY of reduction for CU to the total indoor-outdoor residential estimated
reductions-see #8 above.
The Basin Plan estimates a reduction of about 300 AFY from the Urban Water Use Efficiency Program (which
extends the LOWWP program to urban users outside the PZ). However, this overstates the benefits of the
program, especially since the reductions must be w ithin a few years to add ress the urgent seawater int rusion
problem. As mention, the MWM plan and Basin Plan overstate baseline use to arrive overstated estimates, and
they rely on natu ral conservation over the next 20 years, until2035 (i.e., normal replacement of fixtures/appliances
with more efficient ones as they reach the end of their life spans). The above estimates shows that achieving a 300
AFY reduction within the Purveyor/USL area and a 400 AFY reduction among all Urban users requires a much
more aggressive program that includes leak repair, I 00% washer replacement, and a more comprehensive outdoor
program. The Basin Plan recommends adding only three outdoor measures to the current LOWWP indoor
program for Basin-wide expansion (rain sensor rebates, lim ited outdoor audits, and education). The LOWWP
washer program targets replacing 1665 washers (about one-third ofthe washers in the PZ) at a rate of333 washers
per year for five years. Since January of 2012 (the beginning of the program) only about 15 people have taken
advantage of the $150 rebate and the incentive is clearly ineffective (with washers costing about $700 and washer
replacement not required for hook up to the wastewater project). A conservative estimate is that two-thirds of the
washers in the community could be upgraded for a much greater use reduction.
These estimates indicate that the LOWWP conservation program is likely to produce about a I 00 AFY reduction
reduction is use (70 AFY residential and 30 AFY CII). To achieve the 136 AFY reduction in indoor use within the
PZ, shown above, the Basin Plan would have to target 42 gpcd (not 50 gpcd), replace al l washers, and include leak
repair. End use studies show the reduction in indoor water use from leak repair and efficient washers is equi valent
to the reduction from toilet, faucet aerator, and showerhead replacement, which effectively comprise the current
LOWWP program. If the three outdoor programs recommended in in the Basin Plan are added to the LOWWP
program--and the program per the Basin Plan is extended Basin wide- it may reduce water use another 50 AFY in
the next 5-8 years-half of the claimed 300 AFY. On the other hand, a 470 AFY reduction is possible with a more
aggressive and comprehensive indoor-outdoor program. Again, outdoor reduction estimates above are conservative
if a strong outdoor programs than includes grey water use and rainwater harvesting is impl emented. Also, stronger
recycling program than recommended in the Basin Plan could reduce potable water use in seawater impacted areas
future.
October 22, 2013
Mr. Paavo Ogren, Director
San Luis Obispo County Public Works
County Government Center, Room 207
San Luis Obispo, CA 93408
Email: [email protected]
Mr. Ken Peterson
Golden State Water Company
1140 Los Olivos Avenue
Los Osos, CA 93402
Ms. Kathy Kivley, General Manager
2122 9th Street, Suite 102
Los Osos, CA 93402
Mr. Bill Garfinkel, President
S&T Mutual Water Company
P.O. Box 6391
Los Osos, CA 93412
COMMENTS FOR THE AUGUST 1, 2013 PUBLIC REVIEW DRAFT OF THE BASIN
PLAN FOR THE LOS OSOS GROUNDWATER BASIN (LOS OSOS BASIN PLAN),
SAN LUIS OBISPO COUNTY
Dear Ms. Kivley, Mr. Ogren, Mr. Peterson, and Mr. Garfinkel:
Central Coast Regional Water Quality Control Board (Central Coast Water Board) staff
reviewed the Public Review Draft, Basin Plan for the Los Osos Groundwater Basin (Los
Osos Basin Plan (LOBP). Thank you for the opportunity to comment on the LOBP.
We understand that the primary goal of the LOBP is to establish a long-term,
sustainable approach to manage and protect the water resources of the Los Osos
Groundwater Basin. The groundwater basin is the only source of residential,
commercial, industrial, and agricultural uses in Los Osos and the surrounding areas.
We recognize that the groundwater basin is faced with immediate issues: 1) upper
aquifer degradation by nitrate from septic systems and 2) lower aquifer degradation due
to seawater intrusion as a result of overproduction of the groundwater basin.
The LOBP includes immediate and continuing goals to manage the basin; more
specifically, to halt seawater intrusion and provide sustainable water supplies for
existing and future water demand in the Los Osos community. In addition, the LOBP
describes current baseline groundwater conditions (i.e., water quantity and quality);
describes the legal and regulatory framework surrounding management of the basin
(i.e., Interlocutory Stipulated Judgment); and identifies current challenges facing the
Los Osos Basin Plan Review
-2-
October 22, 2013
purveyors (Los Osos Community Services District, Golden State Water, and S&T
Mutual Water Company or Parties) to cooperatively manage the basin. The LOBP
further identifies various management programs for implementation, such as the Urban
Water Use Efficiency Program, Basin Infrastructure program, the Water Reinvestment
Program and Supplemental Water Program, Well Head Protection Program, and a
myriad of other programs that are intended to achieve long-term sustainable
groundwater basin management.
In order to better understand the efficacy of these programs or combinations of these
programs, the LOBP identifies basin metrics to assess the status of nitrate
concentrations and seawater intrusion in the Basin over time. The LOBP further breaks
the basin metrics into four basic categories: 1) nitrate metrics – measure nitrate
concentrations in the upper basin over time, 2) water level metrics – measure basin
levels to evaluate freshwater pressure gradients, 3) chloride metrics – measure chloride
concentrations in the lower basin over time, and 4) basin management metrics –
measure the overall basin yield over time. The LOBP also provides discussions of
programs recommended for immediate implementation and continued implementation
as well as program funding.
The Central Coast Water Board recognizes that the Los Osos Basin Plan is not subject
to a formal public review process. That being said, we appreciate the opportunity to
review and comment on the LOBP. In general, we support this plan as it is an integral
part for the management of water quantity and water quality in the Los Osos basin.
GENERAL OBSERVATIONS AND COMMENTS
Comprehensiveness and Completeness – We recognize that the LOBP is very
comprehensive and covers a variety of areas necessary to understand and establish the
current status of the basin. In addition, the LOBP includes a comprehensive evaluation
of historical studies, groundwater monitoring data, groundwater modeling, census data,
and other relevant documents to establish a baseline for the immediate and continued
management goals. However, we observe various assumptions that must be made in
order to establish the basin’s current production and demand. For example, water use
estimates for private water users are based on high, medium, or low water usage
depending on square feet of irrigated turf. Even though the LOBP establishes a 20
percent safety factor on such estimates, the LOBP should develop a scheme that can
identify methods for obtaining better and more accurate data.
Iterative Process – We recognize that the LOBP is a living and dynamic document that
will improve over time (i.e., increased data quantity and quality, increased basin
information, increased understanding of consumption over time). As such, we believe
that if the LOBP is updated on a regular basis, the information contained will improve
and thus the basis for which programs are developed will improve. This iterative
process will allow each of the purveyors to evaluate and improve their individual and
collective activities to benefit the basin.
-3-
October 22, 2013
Data Reliability – A key LOBP component is the accuracy of the data used to establish
the baseline groundwater conditions and associated programs. We understand that the
LOBP is not detailed enough to discuss data reliability as it pertains to existing meters
and pumping records. We also believe that the LOBP should be an overarching
management plan and should not necessarily dictate the specific daily operations of
each water purveyor or user (agricultural and private well owners). However, we
encourage water purveyors to establish a quality assurance program that will ensure the
quality and accuracy of the data. Frequent quality assurance checks might be
administered to create a strong foundation for the implementation of proposed
programs. For example, the groundwater monitoring program might incorporate a
quality assurance program that will establish trust when evaluating the nitrate and
chloride metrics.
Implementation Goals and Timelines – The Central Coast Water Board understands
that this is a general planning document to provide guidance and analysis for the
protection and safe production of the Los Osos Groundwater Basin. That being said,
the LOBP does not include any implementation schedules or key milestones that are
required for recommended program implementation. We believe that a key component
to establishing a strong program is to establish a schedule to implement the
recommended “immediate” programs.
Do the Parties plan to develop an
implementation schedule subsequent to the LOBP? We encourage them to do so and
to implement the recommended projects as quickly as possible.
SPECIFIC COMMENTS OR QUESTIONS:
Stream Seepage – Section 5.5 identifies four elements that allow recharge to the basin.
One of the four elements includes recharge as a result of in-stream seepage from Los
Osos Creek. In addition, Section 5.4.5. explains that the principal sources of recharge
to the Lower Aquifer (Zones D and E) are leakage through the regional aquitard and instream recharge through the Los Osos Creek stream seepage. However, we did not
find estimated recharge rates through Los Osos Creek stream seepage. Do the Parties
plan to conduct a study to better understand stream seepage recharge?
Basin Production Estimates– In order to establish accurate groundwater production
values, it is vital that accurate data be used. We recognize that the agricultural water
users and private well owners are not metered, and, therefore, precise data may not be
available. The LOBP and supplemental studies attempt to establish a process to
evaluate production rates generating from agricultural water users and private well
users through the use of crop type, land area, estimated irrigation requirements, as well
as other factors. In addition, Section 4.6 establishes a safety factor of 20 percent to
account for inaccuracies with the water production data. A fundamental aspect of the
LOBP will be the annual evaluation of the basin yield metrics. According to Section
6.3.2, the Basin Yield Metrics utilize annual groundwater production to evaluate the
annual basin yield. If inaccurate data are used to calculate the annual basin yield
(Basin Yield Metrics), then the results of the evaluation may not be representative and
therefore may decrease the effectiveness of a specific program’s implementation.
-4-
October 22, 2013
Section 7.5.2. of the LOBP discusses two solutions to obtain accurate information from
the agricultural water users: 1) voluntary reporting and 2) mandatory reporting. We
recommend that the County implement the second option, requiring registration and
metering of wells and reporting of groundwater production.
Brine Disposal – According to the Basin Infrastructure Program, Section 10.3.4., one of
the options to address nitrate in the upper basin is to use a community nitrate removal
facility. This section adds that the nitrate removal system will generate brine at
approximately 15,000 gallons per day (or three truck loads per day). Further, the LOBP
explains that South SLO County Sanitation District wastewater treatment facility is the
nearest brine disposal facility. However, this section does not include a discussion
regarding establishing an institutional agreement with South SLO County Sanitation
District, which would likely need to occur prior to trucking and disposing brine waste.
Depending on the current situation with South SLO County Sanitation District, an
agreement may take added time and effort on the water purveyors’ part. In addition,
hauling and disposing of brine waste at SLO County Sanitation District wastewater plant
may generate additional greenhouse gas emissions, which would counter the efforts of
Assembly Bill 32.
In addition, Section 11.5.1 includes a discussion of desalination for the purpose of
creating supplemental water. This section includes a discussion of the generation of
brine as a result of the filtration process and the construction of necessary infrastructure
options, such as: 1) dispose of brine to Estero Bay, 2) connect with the existing Morro
Bay desalinization plant to dispose of brine, or 3) connect with the Morro Bay/Cayucos
wastewater treatment facility. All of these options will be very expensive. In addition,
disposal of brine may require a waste discharge requirements permit from the Central
Coast Water Board. However, Morro Bay/Cayucos wastewater treatment facility is
currently going through the process of constructing a new treatment facility. Being that
a new wastewater treatment facility will be constructed, the purveyors might coordinate
with Morro Bay/Cayucos staff and evaluate the possibility for brine disposal at the new
facility.
The Central Coast Water Board appreciates the opportunity to comment on the Los
Osos Basin Plan. We understand that this document is a living document and that there
are many assumptions built into the evaluation of future water demand. We understand
that estimated costs, future groundwater conditions, estimated growth rates, and other
external factors play a role in the difficult process to best develop a guidance document
for the future needs. It is our hope that the LOBP will be updated on a frequent basis to
allow the integration of current data and information into the proposed matrices in order
to fine-tune the recommended programs.
-5-
October 22, 2013
We welcome the opportunity to discuss any of the above comments. If you have
questions, please contact David LaCaro at (805) 549-3892 or at
[email protected].
Sincerely,
Digitally signed by Kenneth A Harris Jr.
DN: cn=Kenneth A Harris Jr., o=Central
Coast Regional Water Quality Control
Board, ou=Executive Officer,
[email protected],
c=US
Date: 2013.10.22 19:25:05 -07'00'
Kenneth A. Harris Jr.
Executive Officer
To the ISJ and LOCSD Water Company,
The Los Osos Basin and drinking supply are in severe overdraft after 30 years of not addressing incoming sea
water intrusion. The County of San Luis Obispo in 1983 issued 1240 new building permits, increasing the draw
by 30% at a time when the data showed a crisis ahead.
The current Sewer project was designed and is being built under the County's supervision after 7 years of
confused goal efforts. San Luis County Public Works has done a dismal job addressing water Re-use and
Conservation. They're currently allowing between 8 and 16 Million gallons per day to be disposed into the Bay
during Dewatering operation for Gravity pipe installation in high groundwater areas. Again, the County's
concern for the Basin supply and sustainability is questionable.
This Draft Plan is difficult to understand and appears to have more than a few flaws in the
modeling numbers. These should be reviewed by an outside oversite and corrected accordingly.
1) The Plan also appears to propose that with some $36 million or more NEW GROWTH could be possible.
Until less expensive methods such a Plan A and D are implemented the County should place a water
moratorium on all new usage.
2) Private and Agriculture Well Monitoring. A funded Program for all private wells must be implemented
in order to gauge the success of any future actions to balance the Basin and halt Sea Water Intrusion. This
would be a relatively simple and inexpensive way to monitor Basin use. Private wells normally show almost a
20% REDUCTION in pumping once they are INCLUDED in Basin Management. How can we manage a Basin
when we can't know private well usage?
3) Re-use Design seriously needs a review. The County's Sewer project does close to nothing to guarantee that
treated effluent will get back into any part of the Aquifer. Offsetting Ag use to slow their pumping has been a
failure. Purple pipe options have NOT BEEN DESIGNED for best potentials.
4) Conservation Efforts have been under-implemented by the purveyors and the County. Basin usage is almost
at the stated goal of 50 gallons per day per resident and purveyors have corrected most Leakage. The $5 Million
included in the County's Conservation program as part of the Sewer project have barely been applied. A major
education program should be put into action, as most Basin users are still UNAWARE of the severity of the Sea
Water Intrusion.
5) Before this Plan is rubber stamped... I would urge an open workshop with an OUTSIDE Oversite guru to
look at corrected data modeling and simplify the options based on affordability, a viable schedule for
implementation, and long-range solutions to stabilize the Basin.
6) No NEW Growth UNTIL 5 years of solutions have been reviewed and there is verification that some new
growth can occur without damaging a sustainable future supply.
Please allow more serious work on this long awaited Basin Plan. A second review could address the flaws and
give our Basin a chance to survive. Taking the politics out of the decision will go a long ways towards a healthy
protected Basin.
Thanks,
Linde Owen
23 yr resident
1935 10th B, Los Osos
805 528-6403
To Whom It May Concern:
I have just a few comments that I would like taken into consideration:
-I believe the planning should be at the no further development as Los Osos does not
have the water resources to support another 5-14 thousand people. Just look at the mess Paso
Robles is in with regards to water.
-I realize that the water board may not have a say in the development of the area,
however for the water usage alone McDonald's should not be allowed to go in on LOVR as is
currently being looked at.
-I oppose a supplemental groundwater desalination project
- I oppose imported water
-I would suggest rebates of some sort for removing lawns and putting in landscape that
is drought tolerant, such as natives
-I also suggest grey water system rebates, and/or programs for converting old septic
sites on the properties of the homes which are going to be hooked up to the sewer
-if in the future water usage per household is looked at I hope that it is not on a system
that expects each household to decrease usage by X amount and instead takes into account
those households who have long ago converted to low-flow appliances, toilets, etc.
-the cost of this project appears immense and I question the individual property owner's
fees in the future and hope that it will not be so costly as to drive current residents away. As we
all are aware the current cost of the sewer is $25, 000 per household and future usage costs for
sewer may be as much as $200 a month per property. Add more money for water and it really
gets to be less feasible for many current residents.
Has anyone looked at combining the 3 water companies? It seems that having overhead costs
at each is a waste of money.
Thank you for taking the time to read my comments.
Amber Wiehl
Los Osos resident and proud home owner
1388 13th Street
Los Osos, CA 93402
805-550-0186
Dear Margaret,
Per your request, I have reviewed the Basin Plan and have a couple of comments/questions for you.
I commend LOCSD, GSWC, S&T, and County on the work that went into preparing the Basin
Report. However, as a homeowner in the Los Osos area, I am offended by the statement that the
residents caused it and therefore must pay for the 'fix'. I did not cause seawater to invade the lower
aquifer. Nor did I cause the increase in nitrates in the water in the upper aquifer. I believe that
these acts are not assignable to anyone directly but to acts of god along with the lack of sewers, use
of septic systems, and use of fertilizers in agricultural areas, just to name a few of the culprits. The
lack of rain for twenty years probably caused the level of water in the aquifers to be reduced.
I am not amused that the project must be paid for by the residents. Of course, I am a responsible
citizen and I agree that I should pay a reasonable amount but it is puzzling that approx. 17,000
residents will pay millions! We are already paying for the sewer system! When will the camel's back
break?
Missing from the report, I noted no mention of a desalination plant! Is a desalination plant
possible? Affordable? Doable?
An outreach program to the residents is necessary to provide information on changes to make to
preserve our precious resource. Since the septic systems in the area are going to become obsolete,
how can the residents use the holding tanks to gather rainwater or gray water to use for
irrigation? When residents use permeable surfaces, or remove grass lawns, or exchange water
loving plants for drought tolerant plants, how will they be rewarded? You cannot expect everyone to
pay and pay and when they do the right thing, no reward is cited.
With regards,
__________________________________
Charmaine Henderson
925.212.5264 Mobile
J. H. EDWARDS COMPANY
A REAL PROPERTY CONCERN
October4,2013
LosOsosCommunityServicesDistrict
21229thSt.
LosOsos,CA93402
RE:LosOsosBasinPlanPublicReviewDraftComments
DearGentlemen,
ThefundamentalgoaloftheBasinPlanfortheLosOsosGroundwaterBasin
(BasinPlan)istobalancefreshwatersupplieswithitsdomestic,agriculturaland
environmentalwaterdemands.Givenrapidlyadvancingseawaterintrusionitis
imperativethatwhateverstrategyisimplementedisaccomplishedassoonas
possible.Seawaterintrusionisnotanotherhigh‐riskPossibleContamination
Activities(PCA)threateningfreshwatersuppliesinthelowerconfinesofthe
groundwaterbasin,itistheonlyPCA.TheBasinPlaninappropriatelycontinuesto
focusconsiderableattentiononNitratesasthe“highestrisk”PCA.Presentlythe
communityisspending$173milliontospecificallyaddressNitrates.Thefocusof
BasinPlanactionsshouldbeonseawaterintrusionintheloweraquiferwithagoal
ofslowingorstabilizingtheincursion.
Ithasbeensuggestedthatthecauseoftheseawaterintrusionwedgehas
resultedfromindiscriminantgroundwaterextractionsbythewaterpurveyors.
Whilethelocationanddepthofgroundwaterextractionsareimportant,anequally
importantcomponentrelatestothemanagementofthegroundwaterbasinby
virtueofrecharge.ThecommunityofLosOsoshascontemplatedforover25years
theneedtocollectthesewagefromhomesandbusinessesforpurposesoftreatment
andenhancingwaterquality,butasimportantisthenotionofcollectingthe
wastewaterforpurposesofreturnorrechargetothegroundwaterbasin,especially
theloweraquifer.
Presently,therearefourpartiestotheISJandtheoreticallyparticipantsin
theBasinPlanimplementation.Giventheneedforexpediencyandcost
effectiveness,IrecommendthatSanLuisObispoCountyandtheS&TMutualWater
CompanywithdrawfromtheBasinPlanimplementation.Inthefuture,theCounty
ofSanLuisObispoastheoperatorofthewastewatertreatmentfacilitymustbeat
“arm’slength”fromtheLosOsosCommunityServicesDistrict(LOCSD)andthe
GoldenStateWaterCompany(GSWC).Thisisthecaseprimarilybecausethe
purveyorsmaybepurchasingrecycledwaterfromtheCountyforpurposesof
groundwaterrechargeorotherbeneficialuses.S&TMutualWaterCompanyhasa
completewatersystemincludingnewmetersandstoragefacilities.S&TMutual
representsaboutthreepercentofthecurrentdemandsuponthebasin.
P.O. Box 6070, Los Osos, CA 93412 (805)235-0873 [email protected]
ACQUISITION MARKETING LAND USE REDEVELOPMENT
Thekeytosuccessinbalancingthebasinistosimplifythesuiteofprograms
andhowtheyarefinanced.
ProgramA–IncreaseduseofUpperAquifer
Forthemostpart,ProgramAhasbeenimplementedorisintheprocessof
implementation.ThisincludestheLOCSDSouthBayexperimentalNitrogen
RemovalProjectandtheGSWCBlendingproject.AnintertiebetweenLOCSDand
GSWCisalsopartofProgramA.PresentlyincludedinProgramAisablending
projectattheLOCSD8thSt.well,whichIbelieveshouldbedeferredoreliminated.
The$600,000budgetedforthatprojectcouldbereallocatedfortheinitialstepsof
ProgramCtobediscussedbelow.
ProgramB‐CommunityNitrogenRemovalFacility.
ProgramBincludestheconstructionofacentralizedcommunitynitrogen
removalfacilitytotreatupperbasingroundwaterextractions.Irecommendthis
programbedeferredintothefutureforconsideration.Theprocessofremoving
nitrogenfromthegroundwaterisexpensive.Themaincomponentsofthehigh
operatingcostsincludeelectricityandbrinedisposal.Furthermore,nitrogenisonly
onecontaminantintheupperaquiferofthegroundwaterbasin.Awaterquality
characterizationstudywaspreparedin2006fortheLosOsosCommunityServices
DistrictbyCleathandAssociates.Also,theupperaquiferisnotimmunetoseawater
intrusionaswasevidencedinthemid‐1980’s.Inconsiderationofacentralized
nitrogenremovalfacilityitshouldbedeferreduntilthereisasuccessfuloperating
historyattheLOCSDSouthBayNitrateRemovalFacility.
ProgramC–WesterntoCentralLowerAquiferWells.
ProgramCincludestheinstallationofthreeloweraquiferwellstoshift
pumpingfromtheWesternAreatotheCentralArea.Theprogramcontemplates
GSWCinstallingtwoofthethreewellsandtheLOCSDinstallingthethird.Ibelieve
programCshouldbeoneofthehighestprioritiesforimplementation.Also,itmay
beGSWConlyneedstoinstallonewell,insteadoftwo.Asignificantcomponentof
ProgramCincludesanupgradeintheLosOsosValleyRoadmaintransmissionline
atacostofapproximately1.5million,whichwouldbebornelargelybyGSWC.
Consequently,eachpurveyorwouldincurthecostforanewwellsomewhereinthe
neighborhoodof$1.6million.Anotherimportantconsiderationinthedevelopment
ofCentralArealoweraquiferwellsistoprovideanintertiebetweenthetwo
purveyor’ssystems.Theideaofinterconnectingthesystemsatstrategiclocations
willallowLOCSDandGSWCtheabilitytooptimizebasinmanagement.
Furthermore,theimplementationofnewconventionalgroundwaterextraction
wellsshouldberelativelysimpletodesign,permit,construct,maintainandoperate.
ProgramCincombinationwithProgramArepresentsanexcellentprimarystepin
theefforttostabilizeseawaterintrusionandprovidessomelimitednew
development.
ProgramD‐‐AdditionalEasternAreaLowerAquiferWells
ProgramDincludestheinstallationofthreeEasternArealoweraquifer
wells.TheEasternareawellswouldbelocatedeastofLosOsosCreekandoverlying
theCreekCompartment,alsoknownasAlluvialAquifer.AswithProgramC,I
believetwowellsmaybesufficientincontrasttothethreewellsproposed.I
supportimplementationofProgramDfollowingProgramsA,CandFasdiscussed
below.
ProgramE–UrbanWaterUseEfficiencyProgram
ProgramEisgenerallyassociatedwiththeLosOsosWastewaterProjectand
thecompanionUrbanWaterConservationProgram.Isupportretrofittingtheentire
communitywiththehighestefficiencywatersavingdeviceswhichwilloccurover
time.Idonotsupportfancybrochures,watereducationorawarenessprogramsin
LosOsos.NordoIsupportwaterauditsorotherlaborintensivemake‐work
programs.
ProgramF–SeasonalSurfaceWaterRelease
ProgramFincludestheseasonalreleaseofrecycledwatergeneratedfrom
theLosOsosRecycledWaterFacility(LORWF).Forexample,duringthemonthsof
June,JulyandAugust,whenLosOsosCreekisdry,anoutfallfacilitycouldrelease
approximately300acrefeetoverthethreemonthperiod.Fromahydrogeological
standpointtheloweraquiferisknowntosurfaceor“daylight”justsouthofLosOsos
ValleyRoadinthecreekbed.Figure20,onpage53,oftheplanreflectsthegeology
oftheLosOsosGroundwaterBasin.ThePasoRoblesFormation,knownasQpris
showntosurfaceassuggestedinthelocationidentified.AlsopleaseseeFigure24
onpage61oftheplanwhichshowstheWest‐EastCrossSectionoftheBasin.Please
seeQa(CreekAlluvium)whichconnectstoZoneDandquitepossiblyZoneEofthe
basin.Thisconceptwasanalyzedasfarbackas1987becauseoftheunique
relationshipLosOsosCreekhaswiththeloweraquifer.TheideaofusingtheLos
OsosCreektoreplenishtheloweraquiferisaconceptthatmimicsMotherNature
duringthewetweatherandincludesthenotionofconjunctiveusesand
managementoftheseresources.Thereareanumberofsurfacewaterdischarges
thatoccurinSanLuisObispoCountyundertheNationalPollutantDischarge
EliminationSystem(NPDES)permit.AnNPDESpermitdoeshavea“highbar”in
termsofwaterqualityandwaterquantity.Withrespecttowaterquality,the
purveyorsGSWCandLOCSDaspermitees,wouldcontractwiththeCountyofSan
LuisObispo,asoperatoroftheLORWFforthehighestqualitywater.The
potentialityofanymandatoryminimumpenaltieswouldbeaddressedinthe
contractforrecycledwaterdelivery.Anotherconcernistheestablishmentof
aquatichabitatsasabyproductofthesurfacewaterreleaseandthecontinuing
obligationtomaintaintheartificialhabitat.However,iftheseasonalsurfacewater
dischargerealizesbenefitstotheloweraquiferintermsofrechargeandstabilizing
seawaterintrusionthantheseasonaldischargeissomethingwewouldwanttodoin
perpetuityanyway.
ProgramG–AgriculturalWaterReinvestmentProgram
ProgramGincludestheconceptofdeliveringrecycledwatertoirrigated
agricultureintheLosOsosValley.Todate,theCountyofSanLuisObispohasbeen
unabletosecureparticipationfromanyoftheactiveirrigatedagriculturalists,in
spiteofextensiveoutreachfromtheCountyandtheSanLuisCoastalResource
ConservationDistrict.Theonlyagriculturalintereststhatareparticipating(65AFY)
arethosepropertiesthatpresentlylackadequatewatersupplies.Inotherwords,
theonlypropertiesthatwillreceivetherecycledwaterarethosedonothave
sufficientsuppliesfortheiroperations.Withouttheirrigatedagriculturalists,itis
impossibletorealizeanyseawaterintrusionmitigationbecausethereisno
reductioninextractionsfromthegroundwaterbasin.Thisscenarioisinsharp
contrasttotheprograminMontereyCountyimplementedbytheMontereyRegional
WaterPollutionControlAgency.InMonterey,irrigatedagricultureislocatedvery
closetotheocean.Consequently,theseagriculturalinterestsarepumpingwater
thathashighchloridecontent.Inthatcase,theirrigatedagriculturalistswere
motivatedtoparticipateintherecycledwaterprogrambecauseofpoorwater
qualityandquality.IntheLosOsosValley,theirrigatedagriculturalistshave
abundantsuppliesofhighqualitywaterandarenotmotivatedatalltoreceive
recycledwater.Compoundingtheproblemistheextensionofregulationsbythe
CentralCaliforniaRegionalWaterQualityControlBoardwithregardtoAgOrderNo.
R3‐2004‐0117.Theorderrequiresagriculturaliststocomplywithstringent
monitoringandreporting.Thishasa“chillingeffect”onanyfutureparticipationin
anAgriculturalWaterReuseorExchangeProgrambyirrigatedagriculturalistsin
LosOsosValley.Consequently,itisunrealistictoconsiderProgramGasaviable
optionnow,orinthefuture.
ProgramM–GroundwaterMonitoringProgram
TheGroundwaterMonitoringprogramshouldbefocusedontracking
sweaterintrusionandtheeffectivenessofvariousprogramsonstabilizingthe
sweaterwedge.Ibelieveweshouldcommitlimitedresourcestoanymonitoring
programthattracksNitrates,theredistributionandconcentrations.
ProgramP–WellheadProtectionProgram
TheWellheadProtectionProgramreferstotheprocessofmanagingthe
activitieswithintheLosOsosGroundwaterBasin.Theprogramaddressessuch
issuesassepticsystemmanagement,saltandnutrientmanagementandwell
abandonment,asexamples.Isupportthisprogramtotheextentthatitfocuseson
realthreatstothequalityandquantityofthegroundwaterbasin.Thefocusshould
beontrackingsweaterintrusionanditsthreattothebasinbydisplacingstorage
capacity.
ProgramS‐‐SupplementalWaterProgram
TheSupplementalWaterProgramdiscussesenhancingtheavailabilityof
freshwatersuppliesincludingrainwaterharvesting,stormwatercaptureand
graywaterreuse.Alsoincludedisseawaterdesalination;however,thiswillnotbe
discussedbecauseofitsinfeasibilityforLosOsos.Giventhelimitedcontributionof
freshwatersuppliesfromtheseactivities,Idonotsuggestanyofthesebefurther
consideredinthecontextofthebasinplan.Individualpropertyownersmayon
theirownvolitionpursuesomeoftheseactivities.
ProgramU–UrbanWaterReinvestmentProgram
ProgramUisanUrbanWaterReinvestmentProgramwhichdovetailswith
ProgramE.LikeProgramE,ProgramUisgenerallyassociatedwiththeLosOsos
WastewaterProjectandtheUrbanWaterConservationProgram.Isupport
retrofittingtheentirecommunitywiththehighestefficiencywatersavingdevices
whichwilloccurovertime.Idonotsupportfancybrochures,watereducationor
awarenessprogramsinLosOsos.NordoIsupportwaterauditsorotherlabor
intensiveprograms.
Financing
Theoriginalconceptforfinancingwaterresourceprojectswastoinclude
thatcostinalargerassessmentdistrictformationandbondofferingwhichalso
wouldincludehabitatconservationandsanitarysewerservice.Theformationof
suchanassessmentdistrictwouldoccurunderProposition218.Idonotsupport
theformationofsuchanassessmentdistrictforanumberofreasons.One,the
primaryintentoftheassessmentdistrictformationwastoallowforthetaxationof
propertiesthatwerewithinthebasinandderivedtheirwatersuppliesfromonsite
wells.Thereareapproximately200suchsituatedproperties.Toforcea
contributiontothebasinmanagementbyahandfulofpropertyownerswhile
incurringsubstantialcostsassociatedwithassessmentdistrictsdoesnotmake
financialsense.Thecommunitywouldbespendingadollartocollectfiftycents.
Moreover,thepurveyorshavetheabilityto“payasyougo”forcapitalprojects
throughincrementalwaterrateincreases.Thisisespeciallytrueifthetotalcostof
contemplatedprojectsintheneartermislessthan$10million.Following
implementationofprogramsA,CandF,itwouldbeproductivetoreevaluatethe
possibilityofanassessmentdistrictformation,ifneeded.Withoutawater
componenttoanassessmentdistrictformation,theCountywouldbefreetopursue
suchadistrictformationforpurposesforhabitatconservationandsanitarysewer
service.
MiscellaneousIssues:
PurveyorCapitalImprovementPrograms
WhilethecomponentsofProgramAareincludedintheten‐yearCapital
ImprovementProgram(CIP)fortheLOCSDandGSWC,noelementsofProgramC
areincludedpresently.Inthecaseofeachpurveyor,theCentralArealoweraquifer
wells,twoorthree,shouldbefoldedintotheCIPforeachpurveyorassoonas
possible.
ComputerModeling
Computermodelingofthebasinhasbeenongoingforanumberofyears.For
example,onecomputerrunincludedtheuseofsprayfieldsattheToniniRanch.
Apparentlythiswascompletedtosimulatetheworstpossiblecasescenario.
Atthisjuncture,giventhelimitednumberofdisposaloptionsforrecycledwater,the
computermodelshouldberunusingaseasonal(dryweather)dischargeofrecycled
wateratanoutfalllocationinLosOsosCreek.Bymodelingthisscenarioitmay
provideinformationonhowthebasinandtheseawaterintrusionwedgewillreact.
Also,iftheseasonaldischargeappearsfeasibletherecouldbesignificantbenefitsin
balancinggroundwaterextractionsintheLosOsosCreekAlluvialAquiferorCreek
Compartment.
ImportedWater
Thebasinplandiscussesanimportedwaterprogram.Therearetwo
primarypotentialsourcesforimportedwaterforLosOsos.OneisNacimiento
WaterProject(NWP)andtheotheristheStateProjectWater(SPW).Theresidents
ofSanLuisObispoCountyhavebeenpayingforSPW,includingresidentsofLos
Osos.Presentlythecountyhasapproximately15,000AFYthatisunsubscribed.In
theearly1990’sthethen,CSA‐9A(LOCSD)andthen,CalCitiesWaterCompany
(GSWC)hadeachrequested300acrefeetofSPW.TheBasinPlanindicatesthatfor
1,000AFYofSPWwouldcost$50millionover30years.Thisincludesanannual
costofapproximately$1million,includingdroughtbuffer.Thecapitalcostis
approximately$20million.ThisisconsistentwiththeTechnicalMemorandumof
July2008forImportedWaterpreparedbyCarolloEngineers.Whileimportedwater
maybethelastresort,Iwouldmuchprefer$20millionbespentonSPWthanona
centralizedNitrogenRemovalFacilityforapproximatelythesamecost.SPW
subscribershavereceivedanaveragedeliveryrateof60percent.Thisreliability
canbedoubledwiththepurchaseofdroughtbuffer,makingthissourceofwater
highlyreliable.WithregardtotheNacimientoWaterProject,itissubstantially
moreexpensivethanSPW,especiallyasdepictedintheTechnicalMemorandumand
islargelyaNorthCountyprojectandwilllikelybeusedthere,forthebalanceofthe
SLOCountyentitlement.
RecycledWaterReuseforCemeteryandGolfCourse
TheUrbanWaterReinvestmentProgram(ProgramU)includesthe
distributionofrecycledwatertotheLosOsosValleyMemorialPark(50AFY)and
theSeaPinesGolfResort(45AFY),pleaseseeTable31onpage211.Thisequatesto
overtenpercentofthetotalrecycledwaterproduced.However,todate,neither
enterprisehasexhibitedinterestandtheabilitytoreceiverecycledwater.For
example,inthecaseofSeaPines,theywillnotbeabletoreceiveanyrecycledwater
untiltheMonarchGroveSubdivisionisconnectedtotheLORWF.Theearliestthis
mayhappenisfollowingthecertificationofanLCPamendmentbytheCalifornia
CoastalCommissiontoincludetheMonarchGroveSubdivisionwithintheUrban
ServicesLine.Also,iftheMonarchGroveHomeownersAssociationchoosesto
retainitscurrentwastewaterfacilitiesthenitmayneverhappen.Withregardtothe
cemetery,Ibelievesocialstigmasassociatedwith“sewerwater”willlimitthe
cemetery’ssubscriptiontorecycledwater.LikeProgramGforirrigatedagriculture
itisunlikelythecemeteryorthegolfcoursewillreceiverecycledwaterinthe
foreseeablefuture.
BrodersonLeachFields
TheBrodersonLeachFields(BLF)arescheduledtoreceive448AFYof
recycledwater.TherearesufficientnumbersofuncertaintiesregardingtheBLF
thatitwouldbeprudentto“rampup”dischargesovertime.Thiswouldreducethe
possibilityofrecycledwater“daylighting”downslopeintheMartinTractand
Cuesta‐by‐the‐Searesidentialneighborhoodsandtheresultingliability.Given
limitedagriculturalreuseandnogolfcourseorcemeteryinterestinrecycledwater,
identifyinganalternativetooverloadingtheBLFiscritical.ProgramF,Seasonal
SurfaceWaterRelease,providesa“reliefvalve”for300AFYduringthedryseason.
PurveyorJointFacilities/Intertie
Whileitwasstatedearlier,IbelieveitisimperativethatLOCSDandGSWC
workcloselyandcooperativelyinthesitingofnewloweraquiferwellsinthe
CentralandEasternAreasandintertietherespectivedistributionsystemsfor
optimalmanagementofthebasin.
Cost/BenefitAnalysis
Acost/benefitanalysisshouldbeconductedonanyProgrambeing
consideredforimplementationbythepurveyors.Inlightoftheextremelyhighcost
ofachievingsanitarysewerserviceinthecommunityincludingitstreatmentand
disposal,costsforgroundwatermanagementmustbeminimized.Inotherwords,
withanyProgramwemustgetthemost“bangforthebuck.”Thisalsoincludesthe
limitationofbureaucraticprocessessuchasaWaterMaster,formationofaFacilities
DistrictandtheCourtscontinuinginvolvementinBasinPlanimplementation.
BuildoutDevelopmentScenario
GiventheimplementationofProgramsA,CandFincombinationwith
conservationshouldresultinademand/yieldrelationshipasfollows.Supplyof
3,000AFYminus20percentreservationequals2,400AFYless2,200AFYwhich
representstotalcurrentgroundwaterproductionannuallyincludingconservation
equals200AFYforbuildoutdevelopment.PleaseseeFigure60onpage237.The
remaining200AFYequatestoapproximately850dwellingunitsat.2to.25AFYper
dwellingunit.Presentlythereareabout500vacantlotsinLosOsos.Consequently,
theresultingbuildoutscenariowouldincludewaterserviceforallvacantlotsplus
about350lotsfromnewsubdivisions.Asapracticalmatter,850dwellingunitsmay
representtheultimatebuildoutofthecommunityintheabsenceofsignificant
additionalcosttofurtherdevelopwaterresources.
Conclusion
IsupporttheimplementationofProgramsA,CandFdescribedabove,as
soonaspossible,withthecapitalcosttobefinancedthroughrateincreasesbyeach
ofthepurveyorsonapayasyougobasis.Idonotsupportimplementationof
ProgramsB,GorS,noworlikelyanytimeinthefuture.
Sincerely,
Jeff Edwards
JeffEdwards
cc.
GSWC‐WesStrickland
GSWC‐KenPeterson
CCRWQCB‐DavidLaCaro
CCRWQCB‐MonicaHunter
SWRCB‐DanNewton
CCC‐DanielRobinson
LOCSDUAC‐RonMunds
SLOCo.P&BDept.‐KerryBrown
Hi Margaret,
I seem to recall that our comments on the Draft Basin Plan could be submitted to you! You might be sorry that you
volunteered, but here goes!
I have put my comments into two groups, Typos/Style and Questions/Comments.I think the powers that be did a great
job (finally!).
Thanks for reading in advance if that ghastly task falls to you! See you on Thursday night!
Lynette
Typos/Style
Some of the pages with maps and graphs have like headers and footers but some don't, like pages 60-61, 225 (and
maybe some others).
Mostly the phrase "rates and tariffs" is used, but sometimes we read "rates and charges" (page 197, second paragraph
from bottom). If these are the same, pick one terminology or if not, explain the difference.
Page 125
"Error! Reference source not found." Needs fixing.
Page 236
10.4 has "8-inch piping" and 10.4.2 has "eight-inch piping" and 10.4.4 has "eight-inch" and "12-inch." One or the other
would look better than using both the number itself and the spelling out of the number.
Questions/Comments
Page 1, third paragraph
In the sentence that reads, "The most important goals are to halt seawater intrusion…" I think that parks and
recreational facilities should be included. I am reminded from my weed pulling at Sweet Springs East, that Audubon's
efforts to restore the property are not made easier by their inability to procure a meter. The water tank and the drip line
works, but it is an awkward solution in my opinion. As hopefully and eventually the water crisis lessens, it seems odd
not to include that use if we are allowing for commercial and institutional uses.
Page 18, 2.3.1
The actual ISJ court case refers to Golden State Water "as formerly Cal Cities Water Company," under page 2, point
"A," line 5. Since most of us know it that way rather than Southern California Water Company (apparently its last
actual name), could that be included for clarification to the average reader?
Page 19, 3.2, Immediate Goals, 2
Is the "agricultural development in Los Osos" referring to the basin itself or just ag within the URL?
Page 27
California is not mentioned as becoming a state (September 9, 1850) but the area is mentioned as being a county in
1850. Seems odd.
Page 29
Sweet Springs East is an additional 8.3 acres added to Sweet Springs Central and although a work in progress, it should
get a mention.
Page 58-59
The property holding license #12061 has an unknown location for the water it is allowed to draw and this seems odd.
How are these licenses monitored? Are they monitored?
Page 169, paragraph 3
Is the Los Osos gpcd number listed here (120) for both indoor and outdoor water use? Seems high.
And paragraph 4, (8.2.4) the goal is 95 gpcd for both indoor and outdoor use. The LOWWP is indoor and it is 50 gpd.
This number appears on other pages too. Maybe we need an explanation where this number is from.
If the 218 to do infrastructure improvements for those that have water connections already does not pass, does that
mean vacant lot owners may be delayed further from developing?
Page 210
The leach fields of Broderson and Bayridge are mentioned. We know from the LOWWP that Broderson has a plan for
redoing the leach field there from time to time. What about Bayridge? Is there a plan or is there room for it to be
redone? Also, on page 220, Condition 85 is mentioned. The rehab of percolation fields is mentioned. Does this refer to
Bayridge?
Page 211
The storage area for winter recycled water has been reduced from 50 AF to 37 AF. Broderson is 40 acres? It has aways
been listed as 80 acres.
Page 211-212
Sea Pines shows potential water demands of 45 AFY on the chart on page 211, but 40 AFY on page 212, paragraph 5,
the last sentence says 40 AFY.
Page 213
There is a reference to a chart on page 209, Figure 54 regarding the recycled water return piping. This does not match
the map shown in the Draft Recycled Water Master Plan on page 27 as to where the pipes are going to the middle
school. Which is correct?
There is a reference to storage ponds of needing room for 30AF initially (which we will have as the 37AF pond that we
are getting with the WWTF will accommodate that). But the report states that we will be needing storage at 150AF at
buildout.
1. This seems like a huge amount.
2. What entity - sewer or water - will build this (presumably with a 218 vote)?
3. Where is the discussion of this need?
Page 215
The chart shows a midtown restoration cost of $400,000, but although not used yet and we are not done with the
project, the budgeted amount was $414, 833. Is this due to rounding?
The Crisis Management Plan is to be paid for by the WWTF or the growers?
Page 244-246
This is my personal pet peeve, but there seems to be an eco-blindness to the hazards of graywater. Who monitors what
products go into the wash - Tide with brighteners or people with hepatitis?
Page 270, last paragraph
How are abandoned and inactive wells monitored now (not purveyor wells, we know they are OK!)? Are they
inspected by DPH or the County? Are the water supplies kept safe now from the possible contaminants? Regulatory
processes are mentioned on page 271 but not defined.
Los Osos Community Advisory Council
October 1, 2013
COUNCIL
MEMBERS
2013-2014
District One
Debby Grisanti
Nathaniel Blair
District Two
Jan Harper
District Three
Paul Malykont
District Four
Tom Cantwell
Treasurer
Alissa Feldman
Appointees
Carolyn Atkinson
Secretary
Alan Fraser
Vicki Milledge,
Chairperson
Leonard A. Moothart, President
2122 9th Street, Suite 102
Los Osos, CA 93402
Dear President Moothart:
On September 9, 2013 the Los Osos Community Advisory Council (LOCAC) met in a
Special Meeting to discuss the recently released Basin Plan for the Los Osos
Groundwater Basin. Both LOCAC members and members of the public attended this
meeting and participated in the discussion.
Participants were frustrated by the limited time the public and LOCAC were given to
study and comment on this long and complicated document. We regard this as the
most important document concerning the Los Osos Basin and its impact on our
community’s survival. As such, we, LOCAC, deserve more time to work with this
document to understand it and make meaningful recommendations for actions to be
included in the plan. We respectfully request an extension to December 15, 2013 to
submit further comments and recommendations.
A summary of the comments made at this meeting is below.
Community/LOCAC Members’ Comments
•
The information as modeled in the plan report is not reliable and is not
provable.
•
According to California law, all landowners have rights to basin water
including undeveloped lots, even if that leads to water rationing.
•
The Plan goals are not guaranteed and it is a non-binding agreement.
•
What is meant by “No future development until the Basin is sustainable”?
o
(Sustainable needs to be defined more clearly.)
•
Include consideration of injection wells as part of the plan and creek recharge
measures in order to recharge the lower aquifer and retard the advancement
of seawater intrusion.
•
Include supplemental water programs as part of the plan.
•
Importation involves uncertainties of law and negotiation that can be made
certain by normal human interaction. [Contracts can be negotiated to remove
uncertainties relative to costs and other implementation issues.]
LOCAC P.O. Box 7170 Los Osos, CA 93412-7170 E-Mail: [email protected]
•
Spread the cost of the plan to all users of the basin, including private well
users.
•
Require monitoring of private wells for data collection only.
•
Make the County responsible for creating ordinances to ensure the basin
survives. [County should enact a basin-wide water management ordinance to
implement the most effective measures.]
•
Instead of spending money to create a new assessment district for funding,
include the costs in rate increases to ensure timely implementation.
•
Include drought data in the plan.
•
Enhance recommended programs: Include Infrastructure Program D initially
in addition to Programs A and C and strengthen conservation and reuse
programs.
LOCAC wishes to thank Rob Miller, Los Osos Community Services District Engineer for
attending our Special Meeting and providing detailed answers to our questions
regarding the Basin Plan.
Sincerely,
Vicki Milledge, Chairperson
Los Osos Community Advisory Council
cc: Carolyn Atkinson, Nathaniel Blair, Tom Cantwell, Alissa Feldman, Alan Fraser, Debby
Grisanti, Jan Harper, Paul Malykont
LOCAC P.O. Box 7170 Los Osos, CA 93412-7170 E-Mail: [email protected]
October 4, 2013
To:
ISJ Working Group
From:
Regarding:
Comments on: The Basin Plan
For the Los Osos Groundwater Basin
The Los Osos Community Services District thanks all the members of the ISJ working group for your time
and effort to produce this comprehensive Basin Management Plan as stipulated. The overall quality of
this plan is appreciated. We are eager to have the plan finalize and become a working document for our
entire community. Please accept our comments and suggestion below we hope they are helpful in the
development of the final draft.




Clearly and Definitively Lay Out Timeline and Milestone for Expectations - We believe it is
important for the parties to develop a timeline of their expected results and milestones of the
program combination(s) of choice. In general the success of The Basin Plan relies heavily on the Los
Osos Waste Water Project and therefore the time line of the project appears to dominate the plan.
The timeline of the Basin should be independent of the results of the Waste Water Project.
Clearly and Definitively Define Watermaster and Committees Authority and Duties - The
Watermaster appears to be a vital part of this plan. The final version of this plan should define who
will make up the committee, their duties and what authorities they have. The definition should
include directives of oversight, annual review and public reporting of the progress of the various
programs including Monitoring.
High Priority for Establishing Community Finance District (CFD) - The Urban Water Use Efficiency
Program as stated is critical component to the plan. It will require a paradigm shift in how many
residents think about water. The LOCSD has always been concerned about the cost of this program
for the expected result as there is evidence of more efficient use of money for similar programs in
the county. The plan acknowledges that the County will administer the Urban Water use Efficiency
Program as part of the LOWWP. This of course infers that water customers with property within the
prohibition zone would be paying a majority of the bill. This is a bothersome proposition and we
support measures that will distribute the cost basin wide including the formation of a Community
Finance District (CFD). The ISJ parties should include support for such comprehensive plans in the
plan.
Metering of All Basin Users for Proper and Correct Water Basin Data - Metering of all basin users is
a high priority in order to establish the best data for monitoring the basin. Metering is one the best
practices for basin monitoring. It may be useful to consider using both options of volunteer and
mandatory metering in a sequential time line. Producers may volunteer with the confidentiality
described for a defined amount of time. After that the County ordinance could be enforced.
Regardless the county should make adopting an ordinance a priority and it should be made clear
that metering is inevitable and goals for metering should be outlined.
1

Agriculture Users Need to be Aware and Need to be Included in Process - It is in the best interest of
all involved to make an effort to include Agriculture users in the process as soon as possible.
Consider forming of a committee to contact the non-purveyor producers in order to start a dialog.
Thank you for the opportunity to make these comments.
Sincerely,
Leonard Moothart,
President, Board of Directors
2
Please accept and include these comments in your assessment.
Thank you,
Patrick McGibney
1177 3rd St.
Baywood Park, CA
Page 135, Section 7.5.2, Groundwater Monitoring Program
“While reporting of groundwater production by the Purveyors is necessary, the
Watermaster and Parties will face significant challenges to successful
management of the Basin without the collection and use of data from nonPurveyors. In particular, with over 40 % of Basin production based on estimates,
the Watermaster and Parties may not be able to accurately predict or measure
the effect of the actions to stop seawater intrusion. . .”
1. Comment:
The above focuses on the crux of all my comments. Managing the Basin is not
possible without the cooperation and participation of ALL users. This must be
mandatory and not a voluntary goal to accurately access the sustainability of the
Basin.
Page 1 Section 1.1:
“. . . The Basin Plan . . . goals are to . . . provide sustainable water supplies for . .
. agriculture . . .”
2. Comment:
We, the community, have no obligation or responsibility to the Ag. Industry and I
for one do not want to be paying one cent for their water use. With growing
populations that need water for their very survival, California’s water basins have
become over drafted not by the populace but in most cases, by the Ag industry
which is made up in most parts by multi-national corporations. They have no limit
to the water they can use and no payment for the use of that water. This is a very
contentious issue, but needs to be addressed as we figure out how to save and
maintain our own water basin. The word “share” comes to mind and when the Ag
industry uses over 70% of all groundwater in California; that is not sharing.
Page 3, Section 1.2 Background:
3. Comment:
Figure 2 has to be inaccurate? I moved to Baywood Park in 1973 when we had a
population of less than 3000. Los Osos Valley was mostly cattle and there was
very little production agriculture happening. Your graph shows those to be some
of the highest periods of irrigation. It was about the same time the County
started indiscriminately issuing building permits that agriculture took off in the
valley and has continued ever since. Irrigation has also exponentially increased
ever since. Agricultural interests have not been using conservation, other
sources, or better watering technology – as can be witnessed by all the overhead
spraying being done, yet your graph does not show this. There should also be a
very high correlation between the time agriculture was introduced into the valley
and nitrate levels starting to rise in our groundwater. Ag and private wells are not
monitored, therefore the graph has to be all speculation made with faulty
estimates. Please review your graph and update your findings.
Page 4, Section 1.2 Background:
.” . . build out . . . in the new Los Osos Community Plan (LOCP) to no more than
19,850. . .”
4. Comment:
There should be no further build out from present population until we can
manage our water resource, and that cannot truly be done until monitoring is
done on ALL user wells, which would include agriculture and private wells.
Page 6, Section 1.3.2, Groundwater Monitoring Program:
“Information regarding other production from the Basin will be gained by
estimates, until such time as accurate information can be acquired through
voluntary participation by (Ag.) well owners or a potential County groundwater
ordinance . . .”
5. Comment:
California water laws are obtuse, outdated, and very complicated, but until we
can require monitoring on all water users, we cannot guarantee the sustainability
of our water resource. ALL users of the Los Osos groundwater basin, need be
required to monitor their wells and report that monitoring. Voluntary participation
equates to non-participation, as evidenced by the Paso Robles groundwater
crisis.
Page 31, Section 4.1 Use of groundwater resources.
“. . . The largest proportion of groundwater is extracted for residential,
commercial and community uses . . .”
6. Comment:
How can this be verified or substantiated when Ag wells are not being
monitored?
In closing:
Recharging of our Basin essential. Taken from a quote found on page 208, 9.2.3
”. . . if wastewater is centrally treated and recharged to the ground-water basin,
the entire projected municipal water demand can be met with locally pumped
ground water without inducing seawater intrusion, even during droughts lasting 1
to 3 years. If wastewater is exported from the basin, however, large amounts of
seawater intrusion are likely to occur even if nearly half of the municipal water
demand is met with imported water.”
Agriculture has to be a large part of this equation, and I believe they must be
required to use recycled water when available. It is now being realized that not
only is water the life force of our planet, it is a diminished resource. In 20 years, it
is estimated that 2/3 of the world’s population will be without potable water. That
could happen very quickly here on our Central Coast without immediate and
inclusive water management. Let’s get that in order first before we start
increasing further demand.
This concludes my comments and the time I have been allotted to make them.
This document is an important part of the future of our community; the time
allotted for its review is minimal for its scope. I have requested extensions, which
have been denied. In the “mission statement” for this document and in section
1.7 (Public Review) it is “recognized . . . the need to achieve public support for
the actions recommended in this Basin Plan. . . “ and that public participation in
the governmental process is encouraged. For future documents made available
for public review, I would suggest that a longer time period be made to allow
those of us who do not do this “professionally “, to have adequate time for
reviewing and commenting.
From: Jodi M. McGraw [mailto:[email protected]]
Sent: Thursday, October 03, 2013 8:38 AM
To: Margaret Falkner
Subject: Basin Management plan activities
Dear Margaret~
I hope that this note finds you well. I received the draft Basin Management Plan, and
attempted to review it to identify projects that might need take coverage under the LOHCP, but
was little confused about what might be slated to occur where. Do you have any idea how I
might be better able to identify and outline the projects anticipated to occur to implement the
plan?
Thank you for any assistance you can provide.
~Jodi
Jodi M. McGraw, Ph.D.
Ecologist and Principal
Jodi McGraw Consulting (JMc)
PO Box 221 • Freedom, CA 95019
(831) 768-6988
[email protected]
www.jodimcgrawconsulting.com

From the Desk of Julie Tacker PO Box 6070 Los Osos, CA 93412

Transcription

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