Comments on PSP For Groundwater Sustainability Plans and Projects

  • Jun 19, 2017
  • Comment Letters

Agency: California Department of Water Resources

Subject: Comments on Proposal Solicitation Package for Groundwater Sustainability Plans and Projects

Letter excerpt:

ACWA generally supports the draft PSP, but we have a number of recommendations for clarifications that will help eliminate possible ambiguities and help GSAs focus their applications for possible Proposition 1 funding to assist with preparation of their GSPs.

These recommendations are as follows:

1. Clarify Eligibility Requirements

a) Eligible Project Types – We recommend the scope of Category 1 projects be clarified to remove water supply and other implementation projects from eligibility for Category 1 funding. These projects, including groundwater production wells, wellhead treatment, and connection to an alternative supply, have significant funding available from other programs, and are more appropriately funded from these sources.

b) Eligible Costs and Payment – The PSP on page 7 is unclear why the May 18, 2016 date was selected for the purpose of identifying cost share activities. We recommend that January 1, 2015, the date the SGMA law went into effect, be used for the eligibility of cost share to include costs already incurred towards GSA coordination and GSP preparation as well.

c) GSAs in Probationary Basins – DWR should consider allowing for the eligibility of GSAs in probationary basins since a basin may become probationary because of a small unmanaged area, while a GSA or GSAs are in the process of preparing a GSP. The administrative processes for the State Water Resources Control Board to consider and impose probationary status will not likely conclude before DWR makes a funding its funding decisions and probationary status will not preclude the need for GSAs to prepare GSPs in any case.

Download ACWA’s comment letter

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