B. Description of Proposed Boundary Modification

1. Short Description

   This proposed jurisdictional internal modificationwould shift the boundary between the South American Subbasin (Bull. 118 Basin # 5-021.65) and the Cosumnes Subbasin (Bull. 188 Basin # 5-022.16) approximately two to four miles
2. Type of basin boundary revision

   • Jurisdiction Internal
3. Provide a narrative overview of the boundary modification request and how the resulting modification would affect likelihood of sustainable management.

   See attached file

   Attachment(s):

   BBM Final Description B_3.pdf (106.8kB) Uploaded on 10/18/2018 at 11:01AM
4. List the existing basin(s)/subbasin(s) to be modified by this request

   • 5-021.65 SACRAMENTO VALLEY - SOUTH AMERICAN
   • 5-022.16 SAN JOAQUIN VALLEY - COSUMNES
5. Provide the proposed name for the new basin(s) or subbasin(s)

   n/a

C. Initial Notification and Combination of Requests

1. Was an initial notification submitted to the Department?

   Yes
   List of submitted initial notification for the selected basin(s)/subbasin(s).

   Local Agency	Potential Basin(s)/Subbasin(s)
   Sloughhouse Resource Conservation District	5-021.65 SACRAMENTO VALLEY - SOUTH AMERICAN , 5-022.16 SAN JOAQUIN VALLEY - COSUMNES
   Omochumne-Hartnell Water District	5-021.65 SACRAMENTO VALLEY - SOUTH AMERICAN , 5-022.16 SAN JOAQUIN VALLEY - COSUMNES
   Northern Delta GSA	5-021.65 SACRAMENTO VALLEY - SOUTH AMERICAN , 5-022.01 SAN JOAQUIN VALLEY - EASTERN SAN JOAQUIN , 5-021.66 SACRAMENTO VALLEY - SOLANO
   Omochumne-Hartnell Water District	5-021.65 SACRAMENTO VALLEY - SOUTH AMERICAN , 5-022.16 SAN JOAQUIN VALLEY - COSUMNES
   	5-021.66 SACRAMENTO VALLEY - SOLANO , 5-021.65 SACRAMENTO VALLEY - SOUTH AMERICAN , 5-022.01 SAN JOAQUIN VALLEY - EASTERN SAN JOAQUIN
   Eastern San Joaquin County Groundwater Basin Authority	5-022.16 SAN JOAQUIN VALLEY - COSUMNES , 5-022.01 SAN JOAQUIN VALLEY - EASTERN SAN JOAQUIN
   	5-022.16 SAN JOAQUIN VALLEY - COSUMNES

2. Does this application include a combination of requests?

   No

D. Required Documents for All Modifications

1. A copy of the statutory or other legal authority under which the requesting agency was created with specific citations to the provisions setting forth the duties and responsibilities of the agency.

Attachment(s):

• SRCD_Legal Authority_D1.pdf (159.5kB) Uploaded on 07/23/2018 at 03:04PM

2. A copy of the signed resolution adopted by the requesting agency formally initiating the boundary modification request process.

Attachment(s):

• 2018_6_22 Basin Boundary Mod Resolution_SIGNED.pdf (629.7kB) Uploaded on 07/23/2018 at 03:09PM
• 2016 BBM Resolution.pdf (1.2MB) Uploaded on 07/23/2018 at 03:09PM

3. A map of adequate scale (no greater than 1:24,000; e.g., 1:10,000 is not acceptable) showing the proposed modified basin boundary in relation to the existing Bulletin-118 basin boundary and the local agencies that are within or bordering the existing and proposed basin.

Attachment(s):

• Final D_3_Sloughhouse_BBM_WaterAgencies.pdf (1.5MB) Uploaded on 10/18/2018 at 09:16AM

4. A GIS shapefile of the proposed modified groundwater basin boundaries. Download Existing B118 basin shape file | DWR Spatial Data Standards

Attachment(s):

• 1_Final D_4 Proposed_Consumnes_Basin_DWR_20181017.zip (63.7kB) Uploaded on 10/18/2018 at 09:15AM

5. A GIS shapefile of the political boundaries of any affected or adjacent local agency. Download water agency shape file

Attachment(s):

• D.5 GIS shapefile of adjacent agencies (Zip Containing Various File Types).ZIP (670.9kB) Uploaded on 07/23/2018 at 03:22PM

6. Any information, if necessary, to enable DWR to satisfy the requirements of a responsible agency pursuant to the California Environmental Quality Act.

This request for a change in basin boundaries simply redraws lines on a map to facilitate SGMA implementation and GSA representation and is therefore an "[o]rganizational or administrative activit[y] of governments that will not result in direct or indirect physical changes in the environment," and is therefore categorically exempt from the California Environmental Quality Act (CEQA). (CEQA Guidelines section 15378(b)(5)) The boundary line request is also an action taken by a regulatory agency (i.e., GSA) to assure maintenance and protection of a natural resource or the environment (i.e., groundwater). (CEQA Guidelines sections 15307, 15308.) Furthermore, CEQA is inapplicable because there is no possibility that the basin boundary request, if granted, may have a significant effect on the environment (i.e., "common-sense" exemption). (CEQA Guidelines section 15061(b)(3).)

E. General Information

1. Describe the lateral boundaries of the alluvial aquifer or aquifers that form the groundwater basin and the definable bottom of the basin. The description must be in terms that are clear, definite, and sufficiently detailed to allow an authoritative map of the proposed basin boundaries to be plotted using the given description.

The Cosumnes Subbasin is defined by the areal extent of unconsolidated to semiconsolidated sedimentary deposits that are bounded on the east by the Sierra Nevada and on the South by the Sacramento-San Joaquin County Line (per a 2016 Basin Boundary Modification granted by DWR). The western boundary follows the Cosumnes River from the county line, and then the northwestern/western boundary of Omochumne Hartnell Water District, which cuts northward and then northeast along Grant Line Road, while still also along the northern/northwestern boundary of Omochumne Hartnell Water District, and then continues north/northeast along the San Joaquin Hydrologic Region and Cosumnes River watershed boundaries until turning southward again towards Rancho Murieta and again following the Sierra Nevada foothills boundary to encompass a portion of western Amador County. There is a shallow unconfined alluvial aquifer within the Modesto Formation which ranges in thickness between 100 feet in the eastern portion of the basin to 650 feet in the western portion of the basin. A deeper semiconfined alluvial aquifer is present n the Mehrten formation which ranges in thickness between 200 and 1,200 feet from east to west. NOTE - This section was modified at the request of DWR to provide clarification to the initial basin boundary modification request. The entire text of the original submittal is provided above and has not been altered. The corrected, modified portion of the original submission reads as follows: The western boundary follows the Cosumnes River from the county line, and then the northwestern/western boundary of Omochumne Hartnell Water District, which cuts northward and then northeast along Grant Line Road, while still also along the northern/northwestern boundary of Omochumne Hartnell Water District, and then continues north/northeast along the SRCD jurisdictional line.

F. Notice and Consultation

1. List all local agencies and public water systems affected by the basin(s) modification request.

The following list is of agencies that may be interested in the basin boundary modification request, but they do not necessarily qualify as "affected agencies" or "affected systems" according to DWR's regulations (see 23 C.C.R. 341) because not all will have a jurisdictional area encompassing more, fewer, or different basins than without the modification. In fact, the requested modification is relatively minor and not expected to affect most of these agencies in any material way. In the interests of full disclosure, however, SRCD attempts to list all these agencies here: Omochumne-Hartnell Water District (qualifies as an "affected agency" under the regulations because it will only have one subbasin, instead of two subbasins, within its jurisdictional area with the modification). Galt Irrigation District Clay Water District Southeast Sacramento County Agricultural Water Authority City of Galt Sloughhouse Resource Conservation District City of Elk Grove City of Folsom City of Rancho Cordova County of Sacramento Sacramento County Water Agency Florin Resource Conservation District Sacramento Central Groundwater Authority Rancho Murieta Community Services District Sacramento Regional County Sanitation District Amador County Amador Water Agency Amador County Groundwater Management Authority

2. Explain the methods used to identify interested local agencies and public water systems in the affected basin(s):

Most of the interested local agencies and public water systems in the affected basins have participated for the last 3 years in ongoing efforts to coordinate SGMA implementation both within the Cosumnes Subbasin and within the South American Subbasin. SRCD identified agencies, water systems, and other stakeholders beginning with its public hearing on becoming a GSA and has engaged in extensive outreach ever since. SRCD also was a co-applicant on the initial basin boundary modification request submitted jointly with OHWD in 2016, which included extensive outreach and also included a public comment period where additional agencies and stakeholders were identified. These past actions include: December 16, 2015, Proposed modification discussed in concept at SSCAWA Board meeting. Representatives from Galt Irrigation District, Clay Water District, OHWD, and SCWA were in attendance. December 16, 2015, SCGA SGMA subcommittee meeting, subcommittee discusses GSA status of OHWD and SRCD and potential basin boundary adjustments in South American subbasin. January 13, 2016 - SRCD held a public workshop in the Wilton Firehouse on January 13, 2016, which provided an overview of SGMA and SRCD's intent to become a GSA in portions of the Cosumnes subbasin and seek a basin boundary modification of the basin. SCWA, SCGA, and California Department of Water Resources Staff attended this hearing. January 13, 2016, SCGA meeting: a potential basin boundary adjustment and GSA status of SRCD and OHWD were discussed. February 9, 2016 - SRCD held a public hearing on February 9, 2016 (after notice under Water Code § 10723(b) and Gov. Code § 6066) that again provided an overview of SGMA and SRCD?s intent to become a GSA in a portion of the Cosumnes Subbasin and its intent to seek a basin boundary modification. SCWA, SCGA, and California Department of Water Resources Staff attended this hearing. February 10, 2016: Proposed modification and GSA status of SRCD and OHWD discussed at SCGA Board Meeting. February 24, 2016: Presentation on identical 2016 basin boundary modification at SSCAWA Board meeting. SSCAWA passes a resolution in support of the proposed change. March 22, 2016: SCWA and Sacramento County Board of Supervisors consider a general resolution on basin boundary adjustments within the County. OHWD and SRCD provide comments as to those agencies? proposal, and the item is continued for later discussion. Over the past two years, collaboration has increased with the creation of the Cosumnes Working Group and Cosumnes Technical Advisory Committee. The Working Group consists of all the GSAs in the Cosumnes Subbasin and has regularly convened notice, public meetings monthly between February 15, 2017 to present. The Technical Advisory Group has held more than a dozen public meetings since May 15, 2017. Additional outreach to identify interested local agencies and public water systems (and other stakeholders) including the following: March 2017 - First public workshop July 2017 - Cosumnes Subbasin Website launched (see: cosumnes.waterforum.org) October 2017 - Three public workshops held in Jackson, Wilton, and Galt (included articles publicizing these events in the Galt Herald and River Valley Times) Additionally, many 2x2, 3x3, and 4x4 meetings have been held between SRCD and other agencies in the area, particularly SCGA, OHWD, and the Sacramento County Water AGency, (including workshops hosted by Sacramento County Supervisor Don Nottoli). SRCD also discussed the basin boundary modification and other SGMA implementation issues at its regular board meetings and issued public notices to solicit input from interested parties.

3. Provide information regarding the nature of consultations with affected or interested agencies. Attach and cite any copies of correspondences with local agencies and public water systems and/or any other persons or entities consulted.

Most of the interested local agencies and public water systems in the affected basins have participated for the last 3 years in ongoing efforts to coordinate SGMA implementation both within the Cosumnes Subbasin and within the South American Subbasin. SRCD identified agencies, water systems, and other stakeholders beginning with its public hearing on becoming a GSA and has engaged in extensive outreach ever since. SRCD also was a co-applicant on the initial basin boundary modification request submitted jointly with OHWD in 2016, which included extensive outreach and also included a public comment period where additional agencies and stakeholders were identified. These past actions include: December 16, 2015, Proposed modification discussed in concept at SSCAWA Board meeting. Representatives from Galt Irrigation District, Clay Water District, OHWD, and SCWA were in attendance. December 16, 2015, SCGA SGMA subcommittee meeting, subcommittee discusses GSA status of OHWD and SRCD and potential basin boundary adjustments in South American subbasin. January 13, 2016 - SRCD held a public workshop in the Wilton Firehouse on January 13, 2016, which provided an overview of SGMA and SRCD's intent to become a GSA in portions of the Cosumnes subbasin and seek a basin boundary modification of the basin. SCWA, SCGA, and California Department of Water Resources Staff attended this hearing. January 13, 2016, SCGA meeting: a potential basin boundary adjustment and GSA status of SRCD and OHWD were discussed. February 9, 2016 - SRCD held a public hearing on February 9, 2016 (after notice under Water Code § 10723(b) and Gov. Code § 6066) that again provided an overview of SGMA and SRCD?s intent to become a GSA in a portion of the Cosumnes Subbasin and its intent to seek a basin boundary modification. SCWA, SCGA, and California Department of Water Resources Staff attended this hearing. February 10, 2016: Proposed modification and GSA status of SRCD and OHWD discussed at SCGA Board Meeting. February 24, 2016: Presentation on identical 2016 basin boundary modification at SSCAWA Board meeting. SSCAWA passes a resolution in support of the proposed change. March 22, 2016: SCWA and Sacramento County Board of Supervisors consider a general resolution on basin boundary adjustments within the County. OHWD and SRCD provide comments as to those agencies? proposal, and the item is continued for later discussion. Over the past two years, collaboration has increased with the creation of the Cosumnes Working Group and Cosumnes Technical Advisory Committee. The Working Group consists of all the GSAs in the Cosumnes Subbasin and has regularly convened notice, public meetings monthly between February 15, 2017 to present. The Technical Advisory Group has held more than a dozen public meetings since May 15, 2017. Additional outreach to identify interested local agencies and public water systems (and other stakeholders) including the following: March 2017 - First public workshop July 2017 - Cosumnes Subbasin Website launched (see: cosumnes.waterforum.org) October 2017 - Three public workshops held in Jackson, Wilton, and Galt (included articles publicizing these events in the Galt Herald and River Valley Times) Additionally, many 2x2, 3x3, and 4x4 meetings have been held between SRCD and other agencies in the area, particularly SCGA, OHWD, and the Sacramento County Water AGency, (including workshops hosted by Sacramento County Supervisor Don Nottoli). SRCD also discussed the basin boundary modification and other SGMA implementation issues at its regular board meetings and issued public notices to solicit input from interested parties.

Attachment(s):

• OutreachLetter_PrintFile.pdf (1,018.8kB) Uploaded on 10/18/2018 at 11:02AM

4. Provide a summary of all public meetings at which the proposed boundary modification was discussed or considered by the requesting agency. Attach and cite any copies of agendas and notices published.

Most of the interested local agencies and public water systems in the affected basins have participated for the last 3 years in ongoing efforts to coordinate SGMA implementation both within the Cosumnes Subbasin and within the South American Subbasin. SRCD identified agencies, water systems, and other stakeholders beginning with its public hearing on becoming a GSA and has engaged in extensive outreach ever since. SRCD also was a co-applicant on the initial basin boundary modification request submitted jointly with OHWD in 2016, which included extensive outreach and also included a public comment period where additional agencies and stakeholders were identified. These past actions include: December 16, 2015, Proposed modification discussed in concept at SSCAWA Board meeting. Representatives from Galt Irrigation District, Clay Water District, OHWD, and SCWA were in attendance. December 16, 2015, SCGA SGMA subcommittee meeting, subcommittee discusses GSA status of OHWD and SRCD and potential basin boundary adjustments in South American subbasin. January 13, 2016 - SRCD held a public workshop in the Wilton Firehouse on January 13, 2016, which provided an overview of SGMA and SRCD's intent to become a GSA in portions of the Cosumnes subbasin and seek a basin boundary modification of the basin. SCWA, SCGA, and California Department of Water Resources Staff attended this hearing. January 13, 2016, SCGA meeting: a potential basin boundary adjustment and GSA status of SRCD and OHWD were discussed. February 9, 2016 - SRCD held a public hearing on February 9, 2016 (after notice under Water Code § 10723(b) and Gov. Code § 6066) that again provided an overview of SGMA and SRCD?s intent to become a GSA in a portion of the Cosumnes Subbasin and its intent to seek a basin boundary modification. SCWA, SCGA, and California Department of Water Resources Staff attended this hearing. February 10, 2016: Proposed modification and GSA status of SRCD and OHWD discussed at SCGA Board Meeting. February 24, 2016: Presentation on identical 2016 basin boundary modification at SSCAWA Board meeting. SSCAWA passes a resolution in support of the proposed change. March 22, 2016: SCWA and Sacramento County Board of Supervisors consider a general resolution on basin boundary adjustments within the County. OHWD and SRCD provide comments as to those agencies? proposal, and the item is continued for later discussion. Over the past two years, collaboration has increased with the creation of the Cosumnes Working Group and Cosumnes Technical Advisory Committee. The Working Group consists of all the GSAs in the Cosumnes Subbasin and has regularly convened notice, public meetings monthly between February 15, 2017 to present. The Technical Advisory Group has held more than a dozen public meetings since May 15, 2017. Additional outreach to identify interested local agencies and public water systems (and other stakeholders) including the following: March 2017 - First public workshop July 2017 - Cosumnes Subbasin Website launched (see: cosumnes.waterforum.org) October 2017 - Three public workshops held in Jackson, Wilton, and Galt (included articles publicizing these events in the Galt Herald and River Valley Times) Additionally, many 2x2, 3x3, and 4x4 meetings have been held between SRCD and other agencies in the area, particularly SCGA, OHWD, and the Sacramento County Water AGency, (including workshops hosted by Sacramento County Supervisor Don Nottoli). SRCD also discussed the basin boundary modification and other SGMA implementation issues at its regular board meetings and issued public notices to solicit input from interested parties.

Attachment(s):

• 2018_1_12 Agenda.pdf (481.3kB) Uploaded on 09/27/2018 at 05:25PM
• 2017_11_3 Agenda.pdf (481.7kB) Uploaded on 09/27/2018 at 05:25PM
• 2018_3_9 Agenda.pdf (483.1kB) Uploaded on 09/27/2018 at 05:25PM
• 2018_4_11 Agenda.pdf (482.9kB) Uploaded on 09/27/2018 at 05:25PM
• 2018_5_18 Draft Agenda.pdf (563kB) Uploaded on 09/27/2018 at 05:25PM
• 2018_6_22 Agenda.pdf (558.3kB) Uploaded on 09/27/2018 at 05:25PM

5. Attach a copy of all comments regarding the proposed boundary modification received by the requesting agency and a summary of any responses made by the requesting agency.

SRCD and OHWD previously submitted a similar joint jurisdictional / scientific basin boundary modification request in 2016. That request was subject to public review and comment, and DWR received comments from several entities during that process. Those comments are not included in this request because they relate to the earlier 2016 BBM request. SRCD received one comment letter pertaining to the current BBM request. During the public comment period for this BBM, several public comments were submitted, both in support of and opposing this BBM. The attached files below contain responses to those comments, particularly those submitted by the Sacramento Central Groundwater Authority and the City of Sacramento.

Attachment(s):

• 2018_7_25 SCGA BLM Comment Letter.pdf (732.6kB) Uploaded on 09/27/2018 at 04:21PM
• Attachment to Sloughhouse BBM Comment Response_OHWD Meeting Minutes_June_27,_2018.pdf (155.6kB) Uploaded on 11/08/2018 at 08:12PM
• Final Sloughhouse Response to SCGA and COS Comments on BBM.pdf (124kB) Uploaded on 11/08/2018 at 08:09PM
• Attachment to Sloughhouse BBM Comment Response_Excerpts from SCGA Recharge Mapping and Field Study.pdf (580.4kB) Uploaded on 11/08/2018 at 08:09PM
• Final OHWD Response to SCGA and COS Comments on BBM.pdf (47.5kB) Uploaded on 11/09/2018 at 01:54PM

G. General Existing Groundwater Management

1. Explain how sustainable groundwater management exists or could likely be achieved in the basin:

Attachment(s):

• G.1.docx (1MB) Uploaded on 09/27/2018 at 07:06PM

2. Explain how the proposed boundary modification would affect the ability of adjacent groundwater basins to sustainably manage groundwater in those groundwater basins.

Attachment(s):

• G.2.docx (21.9kB) Uploaded on 09/27/2018 at 06:49PM

3. Provide a historical summary of the sustainable management of groundwater levels in the proposed basin(s) or subbasin(s).

Attachment(s):

• G.3.docx (924.4kB) Uploaded on 09/27/2018 at 07:20PM

4. Discuss potential impacts to state programs resulting from the proposed boundary modification, including, but not limited to, the California Statewide Groundwater Elevation Monitoring (CASGEM), Groundwater Management Plans developed pursuant to AB 3030, Groundwater Sustainability Plans developed pursuant to the Sustainable Groundwater Management Act, any applicable state or regional board plans, and other water management and land use programs.

Attachment(s):

• G.4.docx (21.3kB) Uploaded on 09/27/2018 at 07:09PM

H. Local Support

1. Provide any evidence that sufficient information was provided to affected agencies and systems regarding the proposed boundary modification.

This boundary modification has been continually discussed since first requested by SRCD and OHWD as far back as 2016. The proposed change was noticed and discussed at numerous public meetings of the OHWD Board, public meetings of the SRCD board, and public meetings of SCGA, SSCAWA, and the Sacramento County Board of Supervisors. Representatives from the County, SCGA, and other local agencies attended those meetings. The proposed change, and the rationale behind it, was discussed at the February 10, 2016 SCGA meeting. Representatives from Florin Resource Conservation District, Elk Grove Water District, Sacramento Regional Sanitation District, Golden State Water Company, City of Folsom, Sacramento County, City of Elk Grove, the Nature Conservancy, Rancho Murieta Community Services District, Sacramento County Waste Management, Sloughhouse Resource Conservation District, and Aeroject Rocketdyne were all present at that meeting. On February 24, 2016, OHWD presented information on the proposed change to the SSCAWA Board and its member agencies, and SSCAWA adopted a resolution of support for the change. Representatives from Galt Irrigation District, Clay Water District, Omochumne-Hartnell Water District, and the Department of Water Resources were all present at that meeting. Notice of a public informational meeting being held on March 18, 2016 was distributed to the interested agencies and systems on March 3, 2016 (see attached notices). Notice of the informational meeting was distributed to local agency representatives and area landowners. A list of people who received the notice of the informational hearing via mail and e-mail is attached. Notice was additionally posted at the Wilton Firehouse, and on the OHWD website. That 2016 request was publicly noticed by DWR as well and a public review and comment period was provided and information remained on DWR's website for many months. Additionally, since then, the agencies have continually discussed the boundary change with Sacramento Central Groundwater Authority, Sacramento County, the Water Forum, and other stakeholders in the South American Subbasin. This BBM request has been continually noticed and discussed at numerous board of directors meetings of the requesting agencies (see materials provided in Section F).

2. Provide a list of all affected agencies and affected systems that submitted comments and/or documents in support or opposition to the proposed boundary. The agency submitting their support or opposition for a boundary modification must provide a copy of a resolution formally adopted by the decision-making body of the affected agency or system or a letter signed by an executive officer or other official with appropriate delegated authority who represents the agency or system. Attach copies of the resolution and/or signed letter detailing the support or opposition submitted.

If the regulatory definition of "affected agencies" and "affected systems" is applied, then there technically are no such entities because no local agencies or public water systems will have their jurisdictional or service areas include "more, fewer, or different basins or subbasins than without the modification." (23 Cal. Code Regs.sec. 341(c)&(e)) Regardless, SRCD and OHWD have sought to notify and coordinate with as many possible stakeholders that may in anyway be affected by the BBM. Of that group, the Sacramento Central Groundwater Authority is the only agency that has submitted an opposition letter to this BBM request. (see attached).

Attachment(s):

• 2018_7_25 SCGA BLM Comment Letter.pdf (732.6kB) Uploaded on 09/28/2018 at 12:02PM

3. Provide any evidence that rebuts any opposition to the proposed boundary modification.

SRCD and OHWD remain committed to collaboratively working with SCWA, SCGA, and other local agencies and stakeholders on SGMA implementation and compliance issues for both the South American and Cosumnes subbasins. SCGA's letter raises unsubstantiated concerns and fears and attempts to make the requesting agencies prove a negative, namely that there will not be an afect to SCGA's management of the South American subbasin. SCGA made the same unsubstantiated claims two years ago and at that time claimed it needed more time to understand the effects of this BBM. In that time, the agencies have had numerous conversations regarding this issue, but SCGA has not identified any specific issues or concerns outside of these vague, generalized objections. To date, neither SCWA nor SCGA have identified any physical development, infrastructure, or conjunctive use projects or programs that exist within the area proposed by this application to be included within the Cosumnes Subbasin that might be negatively impacted by the proposed modification; and there does not appear to be any clear evidence that the existing Cosumnes River boundary truly promotes the most sustainable management of groundwater across the basins (indeed, the 2006 SCGA groundwater management plan did not use the Cosumnes River as the basin boundary for the so-called ?central basin,? but instead used the southern borders of OHWD, south of the river, as the boundary). Furthermore, the SCGA letter baldly rests on maintaining the status quo under some unsupported assumption that SGMA implementation will be easier. The requesting agencies do not believe this to be the case and SCGA's assumptions are unfounded. First, because past efforts did not use the SGMA basin boundaries and did not adequately consider the Cosumnes Subbasin or the requirements of SGMA, new analyses and effort will be required. Furthermore, even SCGA's alternative plan that it submitted used a different boundary than its previous efforts and SCGA there concluded that such changes would not affect its managmeent efforts. The BBM here seeks changes of similar, minor magnitude. Granting the BBM will assuage concerns by the Cosumnes Subbasin stakeholders that their interests will again be discounted, and will therefore foster more trust and an easier working relationship between the two subbasins by allowing the most representative local agency GSAs (e.g., SRCD and OHWD) managed the areas within their jurisdictions.

I. Hydrogeologic Conceptual Model

1. Principal aquifer units within requested basin.
2. Lateral boundaries of the proposed basin, including:
   1. Geologic features that significantly impede or impact groundwater flow.
   2. Aquifer characteristics that significantly impede or impact groundwater flow.
   3. Significant geologic and hydrologic features and conditions of the principle aquifer units, as appropriate, including information regarding the confined or unconfined nature of the aquifer, facies changes, truncation of units, the presence of faults or folds that impede groundwater flow, or other groundwater flow restricting features.
   4. Key surface water bodies, groundwater divides and significant recharge sources.
3. Recharge and discharge areas within the basin.
4. Definable bottom of the basin or subbasin.

The department may waive this requirement for an internal boundary modification if the requesting agency is able to demonstrate that the proposed boundary modification is unlikely to affect sustainable groundwater management.

The hydrogeologic conceptual model has not changed since SRCD's and OHWD's initial BBM request and is therefore resubmitted here in its entirety and unchanged with supporting data that was previously jointly submitted to support a scientific boundary change as well. While SRCD and OHWD do not seek a BBM based on scientific reasons, the discussion of scientific reasons to grant the requested BBM is also part of the materials to fully describe and discuss the hydrogeologic conceptual model, and is also submitted here. Also, the applicants believe that DWR could also waive this requirement because the requested BBM is unlikely to affect sustainable groundwater management.

Attachment(s):

• I. Hydrogeologic conceptual model _.pdf (1.5MB) Uploaded on 09/27/2018 at 07:33PM
• K. Technical Studies for science modification_.pdf (3.9MB) Uploaded on 09/27/2018 at 07:33PM

L. Technical Studies for All Jurisdictional Modifications

1. A water management plan that covers or is in the immediate vicinity of the proposed basin or portion of the proposed basin and satisfies the requirement of Water Code sections 10753.7(a) or 10727 by attaching one of the following:
   1. An adopted groundwater management plan, a basin wide management plan, or other integrated regional water management program or plan.
   2. Management pursuant to an adjudication action.
   3. One or more technical studies that cover the relevant portion of a basin or subbasin and adjacent areas.

Attachment(s):

• SSCAWA_GMP.pdf (35.5MB) Uploaded on 09/27/2018 at 07:39PM
• SOUTH_BASIN_GMP_FINAL_2011.pdf (12.2MB) Uploaded on 09/27/2018 at 07:41PM
• SSCAWA_GMP.pdf (35.5MB) Uploaded on 09/27/2018 at 07:42PM

2. A statement of the existing and planned coordination of sustainable groundwater management activities and responsibilities where required.

There are currently seven GSAs that have been established in the Cosumnes subbasin to implement SGMA. (see submitted files) These GSAs collectively account for all portions of the basin. The GSAs have formed a Working Group that holds regular meetings to facilitate collaborating and coordinating their SGMA efforts for the basin. The Working Group maintains a website to inform the public (see: http://cosumnes.waterforum.org/sustainable-groundwater-management-act-sgma). The GSAs applied for and received a Prop. 1 grant to assist in SGMA implementation. Recently, the attached Framework Agreement and Cost Share Agreement were both approved by all GSAs and an engineering/technical consultant has been selected (see submitted files).

Attachment(s):

• Cosumnes-Fact-Sheet-17_Oct19.pdf (4.1MB) Uploaded on 09/27/2018 at 07:55PM
• Cosumnes Framework Agreement.pdf (134.6kB) Uploaded on 09/27/2018 at 07:55PM
• Cosumnes Cost Share Agreement.pdf (325kB) Uploaded on 09/27/2018 at 07:55PM