Connecting the Dots ~ Fred Allebach

Fred Allebach Fred Allebach is a member of the City of Sonoma’s Community Services and Environmental Commission, and an Advisory Committee member of the Sonoma Valley Groundwater Sustainability Agency. Fred is maintenance chair of the Sonoma Overlook Trail Stewards and an active member of the Sonoma Valley Housing Group and Transition Sonoma Valley. As well, Fred has a KSVY radio show on Sunday nights at 8:PM, participates in the Sonoma Valley Action Coalition for immigration issues, and with the Sonoma Climate Coalition.


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150k case wine facility up against groundwater limits

Posted on March 28, 2017 by Fred Allebach

By a recent 5 to 4 vote, the Sonoma Valley Citizens Advisory Commission (SVCAC) approved a new 40,000-square-foot, 150,000-case wine-production facility. The potential project is located at the Carneros Business Park on southern Eighth Street East. The applicant is New Komiza, LLC, or Scribe Winery, going under the name of LandPlan Company. The Permit and Resource Management Department (PRMD) project file number is PLP16-0024

The SVCAC is an advisory body only and the approval here carries no mandate. The next step is the county Planning Commission, where current county PRMD policy will have to be taken into consideration.

Annual water use for the project is projected to be 4.76 acre feet. The applicant cited PRMD policy WR-1u, saying the project is in a Zone 1 water area, and asked for a waiver of a required hydrogeologic study. A Zone 1 water use area means it is located in a major groundwater basin, where presumably there is enough groundwater, and any permitting would be “ministerial”, which is to say, automatic, if all papers are in order. This project is however, “discretionary”, meaning PRMD will have policy say to direct the project to appropriate land uses.

The actual, relevant PRMD policy to cite is: Policy WR-2e (formerly RC-3h). Policy WR-2e reflects that we are in a time of change, on the threshold of the Sustainable Groundwater Management Act (SGMA) and the creation of a SGMA-mandated, Sonoma Basin, Groundwater Sustainability Agency (GSA).

The time is here, now, when groundwater use, and its associated land use has to start focusing on sustainability. As such, policy WR-2e will require proof of groundwater with a sufficient yield and quality to support proposed uses in Class 3 and 4 water areas (marginal groundwater areas), and, importantly, as noted, in the whole Sonoma Basin, which is a Department of Water Resources (DWR) Bulletin 118 at risk basin.

In fact, it is well known and demonstrated, by the Sonoma Valley Groundwater Management Program (SVGMP), that the proposed project is inside what is known as the East Side Pumping Depression, one of two areas in the Sonoma Valley groundwater basin that is losing groundwater from deep aquifers at a rate faster than it is being replenished. Practically speaking, this area is compromised for groundwater. If this does not qualify as a marginal groundwater area, what would?

To paraphrase current PRMD policy, owing to the changing times and the status of the Sonoma Basin as at risk for groundwater sustainability, a hyrdrogeologic study is required of any discretionary project in the Sonoma Basin, regardless of Zone or Class of water use. Policy WR-2e will require test wells or the establishment of community water systems in Class 4 water areas. (This project is not in a Class 4 water area.) Test wells may be required in Class 3 areas.

Continuing to paraphrase PRMD, policy WR-2e will deny discretionary applications in Class 3 and 4 areas unless a hydrogeologic report establishes that groundwater quality and quantity are adequate and will not be adversely impacted by the cumulative amount of development and uses allowed in the area, so that the proposed use will not cause or exacerbate an overdraft condition in a groundwater basin or sub-basin. Procedures for proving adequate groundwater need to consider the Sustainable Groundwater Management Act’s defined undesirable results or conditions, among which are:  groundwater overdraft, land subsidence, and saline water intrusion. PRMD will also consider the expense of such a study, in relation to the water needs of the project.

In accordance with SGMA, PRMD has now integrated groundwater sustainability into its land use policy. Land use that has a large groundwater use component, will not be considered sustainable if SGMA undesirable conditions are present and unmitigated.

SGMA Undesirable results are:
One or more of the following effects caused by groundwater conditions occurring throughout the basin:

  1. Chronic lowering of groundwater levels indicating a significant and unreasonable depletion of supply if continued over the planning and implementation horizon. Overdraft during a period of drought is not sufficient to establish a chronic lowering of groundwater levels if extractions and recharge are managed as necessary to ensure that reductions in groundwater levels or storage during a period of drought are offset by increases in groundwater levels or storage during other periods.
  2. Significant and unreasonable reduction of groundwater storage.
  3. Significant and unreasonable seawater intrusion.
  4. Significant and unreasonable degraded water quality, including the migration of contaminant plumes that impair water supplies.
  5. Significant and unreasonable land subsidence that substantially interferes with surface land uses.
  6. Depletions of interconnected surface water that have significant and unreasonable adverse impacts on beneficial uses of the surface water.

As such, potential undesirable results from this project could be: groundwater well-level impacts on the Burndale Rd. rural residential area, and also for the existing ag uses to the west of 8th Street East. Presumably sustainable use means conserving for the rights and access of existing uses and users, while not adding new uses that will add to more calls for groundwater, and for the possible undercutting of neighbor’s wells.

The cumulative impact on basin deep aquifer groundwater storage, from other proposed projects in the southern Sonoma Basin, such as the Tolay Springs project, should also be taken into account, with a view to the basin as a whole system, not as a Balkanized checkerboard where uses in one area have no effect in other areas.

The Eastside Fault and many wells on the east side are known to have saline water issues, particularly for boron, and arsenic, as a result of contact with thermal waters and volcanic rock. A number of east side small water companies were shut down by the EPA for having non-potable water. If lowered water quality is a SGMA undesirable result, contaminant plumes, or saline intrusion within the east side pumping depression is a salient SGMA undesirable result. The more deep water aquifer depletion in this area, the worse the groundwater quality will get.

It seems clear that there are multiple groundwater red flags for this project. These red flags will be addressed by county Planning and PRMD. That the SVCAC approved the project is basically neither here nor there. A lot of groundwater issues were simply not addressed by the majority.

Here is a PRMP map of the various groundwater availability classes in Sonoma Valley and the county.  The PLP16-0024 project is on the line between Class 1 (major groundwater basin) and Class 3 (marginal groundwater area). As noted, the project is also within the East Side Pumping Depression. The Sonoma Valley Groundwater Management Program has a number of maps that show the east side pumping depression, the map, on page three of this linked pamphlet shows that project PLP16-0024 is right in the East Side Pumping Depression.

There are other more detailed maps showing the gradient of the east side pumping depression. Tables and figures for the SVGMP 2016 annual report show, on page 12, that this project is smack dab in the middle of the East Side Pumping Depression

The East Side Pumping Depression has experienced groundwater depletion at a rate of .8 feet per year for the last 10 years or more. This is clearly a SGMA undesirable result, along with known saline water intrusion, and a developing cumulative lack of groundwater storage in the deep aquifer.  Please see the following article for a general picture of Sonoma Basin groundwater, and saline water intrusion.  Please note also that deep aquifers in the valley are not responsive to rainy season recharge. Once the deep aquifers are depleted, they stay depleted over a long period of time and recharge occurs at a rate past human time scales. To date, no feasible deep aquifer artificial recharging regime has been demonstrated or shown to be effective. There is a recharge pilot project planned for the city’s well #6 in the Veterans parking lot.

To reflect declining groundwater level, PRMD has adjusted its permitting regulations to reflect the findings of the SVGMP, and to be congruent with the coming SGMA, which will require a Groundwater Sustainability Agency, and a Groundwater Sustainability Plan (GSP). The overall goal is to reach sustainable groundwater use, and to have land use planning dovetail with such plans. The following is a quote from Sandi Potter at PRMD, concerning how this project will need to conform to a current groundwater management regime.

“PRMD (“Permit Sonoma”) has formally adopted a policy for preparing a hydrogeologic study. The County Groundwater Availability Map was updated to require hydrogeologic studies of projects within Bulletin 118 medium and high priority basins (the SGMA basins).

“Another new requirement is that the hydrogeologic study consider the existing adopted Groundwater Management Plans (Sonoma Valley and Santa Rosa Plain) and any impacts the project would have on groundwater sustainability (SMGA refers to the criteria as “undesirable results”), specifically declining water levels, saline water intrusion, and adverse impacts to safe yield.”

The applicant has requested a waiver for the hydrogeologic study, and maintains that the project site is in a Zone 1 water use area of the Sonoma Valley groundwater basin. Yet it seems no matter what the SVCAC said in its 5 to 4 ruling, the request for a waiver can’t really be approved, as the land and groundwater use in the East Side Pumping Depression has to account for what is a safe level of withdrawal. Groundwater sustainability in an especially-at-risk area can’t just be ignored or spun out of existence like normal development projects try to do. As mentioned, this is a transition time where applicants will have to get used to new sets of conditions.  That the project is in the Sonoma Basin, and likely within a Class 3 water use area, in the East Side Pumping Depression, this means that a hyrdrogeologic study will have to be produced, and plans made for how groundwater use will be sustainable. In order for the project to be approved by PRMD, groundwater use can’t make conditions worse. There can’t be undesirable results.

There is really no way the applicant can spin their way out of these facts in and on the ground, and the current regulatory horizon, from PRMD, and the coming GSA from SGMA law.

Cost of a hydrogeologic study cannot be the reason a potentially unsustainable project gets fudged in. That would make money, and economy, a higher factor than groundwater sustainability. For good or ill, this project is taking place in California, where the conservation of common pool resources, in this case, groundwater, is seen as important. Yes, property owners have rights, but no right is above a point where it negatively impacts common pool resources. Rights have to be seen not as immutable, but within a context of costs and benefits for the whole of society and the environment upon which society depends.

It seems a foregone conclusion that through accounting for the noted SGMA undesirable results, of declining deep aquifer groundwater levels, loss of aquifer storage, saline water intrusion, and the under-cutting of other deep wells, that this project will be turned down, or forced to mitigate its groundwater use.

Such mitigation may force a down-sizing, and might include the use of recycled water, or the collecting of rainwater from roof tops and stored in tanks or holding ponds. If the surface aquifer in the area can be shown to recharge quickly with rain, perhaps surface aquifer wells could be used when conditions permit. The cumulative mitigation will have to ensure that groundwater levels do not continue to be depleted as a result of this project.

Groundwater water studies and data have already been produced by the SVGMP that show this is an at-risk area within an at-risk basin. No alternate study will magically produce data that says groundwater is just fine in the area of the East Side Pumping Depression. This area is exactly what the SGMA law was designed to address.

The East Side Pumping Depression may not be an appropriate area to be drawing 4.76 acre feet of groundwater per year. If any area should be red flagged for large scale discretionary development, it is the East Side Pumping Depression. If the applicant insists on wanting to try their luck with the county Planning Commission and PRMD, a hydrogeologic study must be made, to show how the project is going to relate to East Side Pumping Depression, and how a safe groundwater yield will be accomplished.

According to SGMA, groundwater levels will have to be sustainable as benchmarked by levels as they stood on 12/2015. With continuing declines of near a foot per year in the East Side Pumping Depression, this area is on an unsustainable trajectory, clearly a SGMA undesirable result. It’s good that PRMD is being proactive and addressing these issues now.

A more appropriate location would be somewhere in the valley that has responsive-to-rain surface aquifer recharge. Even in such a location however, during a time of drought, or during just the normal dry season, high groundwater water use would possibly effect interconnected surface waters and also be a SGMA undesirable result.

The upshot: Sonoma Valley is not a good place for more high-water use projects. Just like with events centers, and the intra-wine industry competition between central tasting rooms and chateaus in the country, more and more use is being pushed for because there is a lot of money to be made. At some point, money can’t just rule the ruining of common pool resources. The county appears to be at the point where money is going to be reeled in, at least in terms of how it relates to groundwater use. Existing groundwater users need to have priority over a limitless stacking of new uses that will ultimately, in aggregate, prove to be unsustainable.

The wine industry is pushing the limits of what this geographic area can sustain, from a social standpoint and from a groundwater standpoint. Centralized production facilities, such as proposed by this project may seem on the surface to be a good idea, but as a whole, this needs to be framed in the big picture of groundwater use, and overall wine production. The Valley and the Basin, have in many ways, already arrived at a place of being more than enough.

Sonoma Valley groundwater is up against a tragedy of the commons-pattern scenario. More actors keep pushing for their own narrow benefit, all the while degrading the common pool resource for all. To address this negative outcome is why the SGMA law was passed. It will the Sonoma Basin GSA’s task to corral all the stake holding interests and forge a regime of cooperation and sustainability. In the meantime, the status of this particular project should be managed by looking forward to a SGMA groundwater sustainability regime, and not backward, to a time of no limits at all.








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