Comments on Draft GSP Emergency Regulations

  • Apr 1, 2016
  • Comment Letters

Agency: California Department of Water Resources

Subject: “Draft GSP Emergency Regulations Public Comment”

Letter excerpt:

A fundamental principle of SGMA groundwater management is that management is performed at the local level. One of the primary goals of SGMA is to “manage groundwater basins through the actions of local government agencies to the greatest extent feasible, while minimizing state intervention to only when necessary to ensure that local agencies manage groundwater in a sustainable manner” (California Water Code, § 10720.1(h)). DWR recognizes the importance of local control, stating in the Draft GSP Regulations that “local control and management is a fundamental principle of SGMA.” Yet, the Draft GSP Regulations are overreaching in places, too prescriptive at times, and certain sections seem to be structured to uniformly manage groundwater basins from a “top down” State level instead of at the local level. Many of these prescriptive requirements appear to be intended to drive local GSAs to prepare one GSP per basin, although such a requirement was explicitly rejected during the legislative process that resulted in SGMA.

Although ACWA recognizes the need for the Draft GSP Regulations to prescribe certain consistent standards which can assist GSAs (and DWR) in plan preparation and review, we have identified many which are unnecessarily restrictive. Some of the more significant examples are noted in the following sections of this letter and are identified in the attached track changes version, where revised text is proposed to resolve specific cases.

Download ACWA’s comment letter

Download letter attachment

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