Susanne von Rosenberg has over 30 years of experience managing the planning and permitting of environmental projects, and supporting the implementation of these projects. She has extensive experience with habitat restoration in the North Bay, including the restoration of the Napa River and Green Island Units of the Napa Sonoma Marshes Wildlife Area (a combined 11,000 acres of habitat restoration). Susanne is a graduate of MIT and has been active in Napa County groundwater issues since joining GULP (Groundwater Under Local Protection) in 2007.

Eyes on Napa: As a member of the Groundwater Sustainability Plan Advisory Committee (GSPAC), you have participated over a year and a half in the formation of the draft Groundwater Sustainability Plan (GSP). You voted to not pass GSP draft. What is your own assessment of this draft as it is proposed?

Susanne von Rosenberg (SvR): My assessment is that a lot of good work has gone into characterizing the conditions in the Subbasin, but that there are some key deficiencies in the Plan due to the County’s goal of meeting the requirements of SGMA vs. aiming for true sustainability, and combination of a lack of clarity, incomplete analysis, and lack of a viable implementation plan. The specific deficiencies in my view are:

1. Meeting the requirements of SGMA – the County’s objective – does not ensure true groundwater sustainability. Meeting the requirements of SGMA is a minimum threshold; the objective should be/should have been to ensure groundwater sustainability for all users in Napa County, including environmental users. When you start out with the incorrect context, it’s hard to produce a good product.

2. Lack of clarity issues:
a. if you read the Plan carefully, and listen to the GSPAC meeting recordings, you will find out that there is considerable uncertainty in the modeling results for groundwater supply and groundwater use (according to the County’s consultant, around 10%in each. The best estimate is that groundwater use and groundwater consumption are generally in balance now (i.e., over an averaging period of around 10 years, withdrawals and recharge are roughly equal). However, if you consider that supply (recharge) and withdrawal estimates have considerable uncertainty, this apparent balance becomes questionable. If these uncertainties had been highlighted more clearly, a stronger case would have been made for requiring monitoring of groundwater extraction at all wells.

b. the Plan concludes that there will be an increase in groundwater demand due to climate change, as well as a decrease in supply for the same reason. The net change in groundwater would be an increase in groundwater need of nearly 2,000 AFY (reduced supply combined with increased demand). The implications of this (roughly a 12 – 13% increase relative to the estimated average current groundwater use) are not clearly described in the GSP, and are not specifically addressed (the Plan assumes that the adaptive management process included in the implementation strategy will be responsive enough to identify downward trends in groundwater supply and react in time to avoid major issues).

3. Incomplete analysis:
a. the County’s consultant indicated that none of the three climate scenarios recommended by DWR as a basis for modeling future conditions included the extreme dry years that we have just experienced.
Nonetheless, the Plan’s analysis and conclusions are based on those scenarios because they were recommended by DWR (and therefore meet SGMA requirements). At a minimum, the Plan should have clearly articulated the fact that the basis of the modeling was likely too optimistic; if true sustainability had been the goal, an additional modeling scenario should have been constructed to evaluate potential conditions under more extreme dry conditions.

b. Model vs. reality – in any situation where modeling is used as a basis for evaluating future conditions, on-the-ground reality should be the final test. On-the-ground reality tells us that the Napa River is suffering; long-term residents cannot remember the river ever going dry, even during the extreme drought years in the late 70s (which seem to have had similar levels of rainfall as we had the past two years). In other words, the modeled conclusion that “everything is currently ok” is not supported by the on-the-ground reality. The Plan does not address this issue, and as far as I can tell there was no effort made to collect historical anecdotal information to inform the Plan/provide a comparison of current vs. past conditions. While anecdotal evidence is not a gold standard in terms of scientific evidence, it can be an important contribution when scientific evidence is lacking.

4. Lack of a real implementation plan. The GSP was prepared and presented to the GSPAC in pieces, due to time constraints. The most important (in my opinion) portion of the Plan is the implementation plan in Section 11. This Section is terribly deficient. Currently, Section 11 contains some general concepts and strategies, but nothing that I (who have spent my career as a project manager for a variety of environmental projects) would consider even close to a real plan. It lacks specific actions (the only specific actions are the formation of a technical working group and the installation of 4 additional sets of monitoring wells to evaluate groundwater/surface water interactions). The “schedule” is so general as to be meaningless. The implementation plan should have had additional actions (e.g., a specific date by when all groundwater extraction wells will be monitored, including a timeline for passing an ordinance requiring that to be done). I had numerous comments on Section 11. I have not gone back line by line to see if my comments were addressed. The only commitment from the County was to address typos and clear errors. The County was not able to provide a redline version of the revised Section [to afford more easy checking if Susanne’s comments were addressed].

5. Inadequate review time: Reviewing a document in sections works on some level, but it’s still really important to be able to review the document as a whole. The GSPAC timeline did not allow for that, and the preparation of Sections 11 and 12 was really rushed. Several of us on the GSPAC had asked at the start of the process (when the Plan review/preparation schedule was first presented) that the County allow a minimum of 30 days for review of the complete Plan prior to preparation of the draft to the BOS. I offered to help brainstorm to revise the schedule, but the County did not choose to modify the schedule or reach out for help to the GSPAC to figure out how to improve the review process.

EON: A number of people feel that GSPAC is heavily weighted with Ag representatives. Do you agree?

SvR: I feel that the composition of the GSPAC is weighted toward the wine industry; although there aren’t a disproportionate number of direct ag representatives, some of the other representatives have strong wine industry ties.

EON:.Beth Milliken proposed (and GSPAC unanimously supported) that the Groundwater Sustainability Agency (GSA) appoint a Technical Work Group (TWG) with strong people to advise and implement the GSA. What are your thoughts on this?

SvR: I’m thrilled that the Plan includes a strong recommendation for a TWG. In effect, the TWG would help craft the implementation plan that should have been contained in Section 11, and would also manage the adaptive management process. I am concerned about the ways this could go wrong, primarily through the selection of the wrong participants. I have been clear in my position that the members of the TWG must be independent if the TWG is to fulfill its intended function. By independent I mean public agency personnel and academia; the TWG should not contain wine industry or Napa County government representatives. The County could hire consultants to support the TWG, but these consultants would have to be accountable only to the TWG.

EON:.The Board of Supervisors (BOS) has appointed themselves to be the GSA. In communications from the Department of Water Resources, we have discovered that this is legal. What is your opinion of this? What are the pros and cons?

SvR: Napa County lacks a single agency tasked with protecting/managing groundwater and surface water. The BOS should have formed that agency, and that agency should have overseen the preparation of the GSP. I see no real pros for having the BOS be the GSA, except that it could be argued that it will be easier to get decisions made when there is only one layer of government (I’m not sure that that is actually true). The cons are many and fairly obvious: 1) the members of the BOS rely on donations during their election campaigns and are therefore subject to political influence. 2) The BOS already has a very full plate, and it can hardly be reasonable to assume that the entire BOS will become conversant enough with groundwater science/issues to make good decisions, especially if those good decisions are potentially controversial in some quarters. Relying on overworked County staff is not a solution. 3) the GSA is only one of the Napa County agencies engaged in groundwater and surface water management and must coordinate with other County agencies and outside agencies [there is no plan for how to do this in the GSP, by the way]; doing so at the BOS level is cumbersome.

EON:.A criticism of the draft GSP and of the process whereby it was written is that it has a narrow focus on the Napa subbasin and doesn’t include the health of the watersheds that sustain it. What are your thoughts on this?

SvR: I agree that the GSP is too narrowly focused on just the Subbasin. In my view, the narrow focus was a desirable outcome for the County and part of the intent of focusing on only fulfilling the requirements of SGMA vs. achieving true sustainability (the two objectives are not in conflict, achieving true sustainability would in part require fulfilling the requirements of SGMA). If one assumes that development in the hills means that precipitation that would otherwise percolate into groundwater or become run-off to our local creeks/the Napa River, then allowing the remaining development on the hillsides (Mike Hackett indicated that this would be on the order of 5,000 acres) could remove as much as 2,000 AFY combined of run-off and infiltration from the Napa County water supply (0.4 AFY/acre of vineyard). Additional water demand would be created by wine production from these 2,000 acres of grapes.