From: Amber Manfree April 30, 2022
Attn: Department of Water Resources
RE: Napa Groundwater Sustainability Plan Comments

To whom it may concern:
After having time to review the entire second draft Groundwater Sustainability Plan (GSP) and reflect on the Groundwater Sustainability Advisory Committee (GSPAC) process, my personal comments on both are presented here.

When the Sustainable Groundwater Management Act (SGMA) was adopted in 2014, it was a response to drought conditions in contingency with climate change raising the specter of long-term of water supply instability in California. In the eight years since that time, conditions have deteriorated further. Climate scientists have declared a megadrought in the US west. Delta Smelt populations – a harbinger of environmental change in the SF estuary – are now so low that hatchery-bred fish were released for the first time in December of 2021. Enormous and destructive fires have ranged up and down the state, including several in Napa County.

Widespread drying of the mainstem Napa River occurred in the summer of 2021, resulting in fish kills, and the river will no doubt dry again in summer of 2022. Dropping groundwater levels and dry wells have been reported by residents, and there has been a notable uptick in new well drilling. Amid this backdrop, the Napa Groundwater Sustainability Agency has submitted a plan that fails to adequately describe or address groundwater scarcity.

My research specialty is Landscape Change Geography. This field integrates numerous disciplines (geology, hydrology, ecology, social science, and others) to explain change over time and predict outcomes of various trajectories depending on which choices we make today. As a life-long Napa resident, insight from my academic background translates directly to understanding how policy will impact friends, family, and natural systems.

The megadrought currently underway has historical parallels, and cannot be attributed to anthropogenic climate change entirely. The paleoclimate record suggests that water managers should plan for a drought which may last decades to centuries, and will be compounded by climate change.

The draft GSP only prepares us for an impossibly optimistic best-case scenario. It does so by over-estimating the reliability of surface water supplies and through a failure to adequately monitor and measure groundwater and connected surface water. This puts Napa’s environmental users of water, residents, and businesses in a poor position for managing the shared groundwater resource.

The Napa County Groundwater Sustainability Agency (GSA) has an opportunity to establish a meaningful, place-based policy to ameliorate the conditions that are likely ahead. But it can only do this by being honest about current and projected conditions, and with adequate monitoring and measuring.

Municipal supplies and trends in development (sections 7 and 8)

Drinking water and groundwater supplies are interconnected and thus interdependent. Plan projections of surface water supplies assume a best-case scenario, where the majority of State Water Project deliveries will always be available, and reservoir operations are never compromised by drought,
cumulative demand increases, or disaster. The North Bay Aqueduct extends from American Canyon to Calistoga and is considered a back-up in the event that other water sources are unavailable.

In reality, Napa County reservoirs are increasingly at-risk from upstream development and sedimentation and/or pollution following fires. Municipalities are already negotiating water swaps to cover their needs and North Bay Aqueduct deliveries have been curtailed to 5% in 2022. North Bay Aqueduct water is at-risk from salinity intrusion, warming temps, and earthquakes, and should not be considered a fail-safe water source. The draft GSP fails to acknowledge these relevant circumstances.

Agricultural development in tributary watersheds is ongoing. An average of 500 acres per year are converted from wildland to vineyard in Napa County (Napa County data). Although cities and the California Veteran’s Affairs office manage reservoirs, development permits are managed by the County of Napa and cumulative impacts on reservoirs are not considered. Each acre of vineyard requires 1⁄2 AF/yr in irrigation, and more for new plantings and in drought. Much of the land being converted is above water supply reservoirs, and eutrophication and fine sediment are increasingly problematic at reservoirs with very developed watersheds.

Development on the floor of Napa Valley (largely coincident with the Napa Valley Groundwater Basin) is also steady, with about 800 additional acres land converted from open space or agriculture to urban land cover since 1993 (Napa County data). The additions are mostly tourist facilities, new and expanded wineries, and large homes with lavish landscaping. Each of these projects brings additional pressure on groundwater in the unincorporated area. Each additional gallon of wine permitted requires six gallons of (mostly) potable water to produce. Like wildland to vineyard conversion, the rate of conversion to urban uses on the valley floor is continuing and not expected to slow in the near future.

Wildland to vineyard conversion outside the basin is a concern in managing the balance of water available to communities in Napa County because demands on groundwater in the upper Napa River watershed are steadily increasing. Similarly, increased development within the basin is a concern. Overly-optimistic projections for groundwater recharge and under-estimation of cumulative demand are pervasive flaws of the Napa Valley GSP. Development trends should be discussed in the report in the context of increasing pressure on groundwater supplies both above and below reservoirs over time.
The City of St. Helena is heavily reliant on groundwater withdrawals, and is therefore especially sensitive to poor basin management. Risks and contingencies should be described briefly in the GSP. Related impacts on groundwater demand should be fully assessed.

All models are wrong, some are useful (George Box, 1976)

Connections between groundwater availability, land use planning, and drought are not adequately contemplated in modeling. It is imperative that trends in development and water use are accurately represented so that appropriate management tools can be developed and deployed.

For reasons mentioned above, Napa Valley GSP model inputs are overly optimistic. They presume that there will never be a substantial reduction in water supply from the North Bay Aqueduct and that the driest year we will see is only slightly drier compared to observed long-term averages. They assume that precipitation patterns in the future will look a lot like the past – something that climate science tells us absolutely will not be the case in our region.

Modeling should incorporate land-use change trends and more extreme drought conditions and test system thresholds. A possible alternate or additional approach would be to assess tipping points or system thresholds and relate them to management actions.

Climate change

SGMA requires that climate change projections be incorporated in planning. The past few years have produced increasingly non-linear real-world outcomes in a variety of natural resource management metrics (snowmelt, fire, drought intensity). This is alarming, and the longer that planners wait to consider these conditions, the fewer choices we will have in the future. Addressing conditions that diverge from the historical record in nonlinear ways may be beyond the capability of current models, but it is imperative that the Napa GSP enumerate and discuss those real-world conditions.

Management Actions and Environmental users

Linkage between ambient surface water-groundwater conditions, monitoring, triggers for actions, and the actions themselves is not expressed with clarity in the Napa Valley Basin GSP. That leaves a broad area for interpretation and implementation. The primary risk is that if monitoring isn’t adequate, triggers will not be activated when they should be, and management actions won’t happen when they need to. This is the weakest section of the Plan, effectively ensuring that environmental users will be the first to suffer in times of average and below average groundwater availability. By avoiding mechanisms by which actions might be taken, we are effectively assured that they won’t be.

See Appendix 1 for further discussion on environmental users.

Problematic Process Framework

The purpose of public process in SGMA, is to incorporate relevant commentary to produce a better plan. Contrary to this, the structure of the GSPAC process, agenda-setting, and conduct by representatives of Napa County during meetings reinforced an avoidance of relevant science and public input.
• At the outset of the process, decision makers publicly stated that they were only considering community members who “played well with others” for seats on GSPAC. This reinforces one of the primary reasons that stakeholders and NGOs don’t speak truth to power; because they feel that if they do, they won’t have a seat at the table.
• GSPAC members were required by the GSA to sign a legal document preventing them from having discussions with, or lobbying, DWR and other state employees about Napa’s GSP before being confirmed to GSPAC
• I urged the GSA and county staff to find ways to effectively outreach to, and include, disadvantaged communities and people of color during the first few months of meetings. After assuring me that they would look into options, no action was taken. Details available upon request
• As a scientist with a good understanding of climate change and impacts of groundwater overdraft on aquatic systems, I repeatedly pushed for better assessments of environmental users of water, adequate monitoring of groundwater-surface water connections, and establishing biological indicators. In response, staff repeatedly facilitated GSPAC process away from of discussions about what needs to be done locally to achieve long-term sustainability. The result was that there was no substantive discussion of cumulative impacts of use, relationships between uses, or assessments of environmental users.

• Sierra Club of Napa wished to present a series of concerns and participate in discussions related to those points at a public meeting of GSPAC. County staff denied the request, instead conducting a private Zoom meeting with Sierra Club where staff enumerated their objections to Sierra Club representatives participating in a discussion during a public meeting. The primary objection was that, if one group was allowed to participate in this way, other groups would have to be allowed, as well. When Nick Cheranich presented on behalf Sierra Club during public comment following this incident, County staff interrupted and rebutted his comments while he was speaking. (Pers. comm. Roland Dumas).
• Points raised by community members at GSP public meetings are not reflected in the final draft GSP. Complete video recordings of these events are available for September 22, 2021, and September 29, 2020.


Stepping back and looking at the bigger picture, environmental advocacy in stakeholder negotiation often functions from a baseline or status quo of current conditions and practices which are typically very compromised already, so the “ask” from those concerned about the environment is basically, “Can we please stop digging the hole deeper?” Therefore, meeting in the middle results in something like, “OK we’ll slow down the digging.” From the environmental standpoint, this really isn’t a win, or even a compromise. It just buys a bit of time before the same unfortunate end result is reached.

Napa River watershed is in relatively good condition, compared to other areas in the region. Napa Valley has the benefit of an agricultural community that is, compared to others, highly invested in sustainability as a goal and marketing strategy with the potential to be a leader in “regenerative” approaches to land management. Napa has a lot to save and is in an incredibly strong position to get it done.

The world is changing rapidly around us. Climate change presents an unparalleled opportunity to enact holistic change, to reimagine our social and built environments, and for a fresh assessment of our relationship with the nature. At its best, SGMA will be at the leading edge of climate-appropriate planning. However, if it is not stridently applied, GSPs will serve as variety of climate denial in policy form.
Each GSA should be held to a high standard in both plan content and implementation. I urge you to pursue this goal in the Napa Valley Basin and in all GSP reviews.

Thank you,
Amber Manfree