B. Description of Proposed Boundary Modification

1. Short Description

   Merge a portion of the South American Subbasin into the Cosumnes Subbasin.
2. Type of basin boundary revision

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

   Omochumne-Hartnell Water District (OHWD) and Sloughhouse Resource Conservation District (SRCD) currently have service areas in both the Sacramento Valley South American Subbasin (5-21.65) and the San Joaquin Valley Cosumnes Subbasin (5-22.16). The existing groundwater basin boundary along the Cosumnes River splits OHWD into both the South American and Cosumnes Subbasins and also results in a portion of SRCD being within the South American Subbasin while most of SRCD lies within the Cosumnes Subbasin. The proposed modification would shift the boundary of the Cosumnes Subbasin north so that all of OHWD and virtually all of SRCD would lie within the Cosumnes Subbasin. The new northern boundary of the Cosumnes Subbasin would follow the OHWD and SRCD northern boundaries which coincide with Grant Line Road, and then further follow the Cosumnes River watershed boundary to the northeast, which closely follows SRCDs jurisdictional line. Historically, the area covered by this boundary modification request has been analyzed in groundwater management plans (GMPs) promulgated by both Sacramento Central Groundwater Authority (SCGA) and Southeast Sacramento County Agricultural Water Authority (?SSCAWA?). However, the land uses and hydrology in the proposed modification area are more consistent with the Cosumnes Subbasin than the South American Subbasin. The existing GMPs for this area must be reconciled regardless of the determination on the proposed boundary modification as none of the existing GMPs for this region conform to the current or the proposed subbasin boundaries. There appears to be scientific justification for the proposition that the Cosumnes Subbasin does not stop at the Cosumnes River centerline, as currently described, but actually extends northward to the edge of the Cosumnes watershed, as is proposed here. As further described in Section G of this basin boundary modification request, the proposed modification would promote the likelihood of sustainable management and the establishment of a groundwater sustainability plan in the Cosumnes Subbasin by providing leadership to the Subbasin, focused local control within public agencies jurisdiction, decreasing the isolation of regions with limited economic and staff resources, and creating better integration between surface water and groundwater boundaries. Because the he existing groundwater management program in the South American Subbasin is not dependent on the participation of OHWD or this region to maintain sustainability, and because of the strong existing funding and infrastructure in that region, the proposed modification is not expected to diminish the establishment of a groundwater sustainability plan or sustainable management under SGMA in the South American Subbasin.

   Attachment(s):
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?

   Yes

   If yes, describe:

   This combined basin modification request is submitted by both Omochumne-Hartnell Water District and by Sloughhouse Resource Conservation District, as directed by § 343.6 of the Department?s Groundwater Basin Boundary Emergency Regulations. OHWD and SRCD share a common boundary over a portion of the modification request, and the initial notifications submitted by those agencies covered overlapping areas of the San Joaquin Valley Cosumnes Subbasin and the Sacramento Valley South American Subbasin. To prevent duplicative and/or conflicting requests, the requesting agencies coordinated closely on the boundary request via numerous meetings and frequent communication in order to prepare a single modification request. The request submitted by Eastern San Joaquin County Groundwater Basin Authority does not conflict with this request.

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):

• OHWD_Legal Authority.pdf (2MB) Uploaded on 03/30/2016 at 03:13PM
• SRCD_Legal Authority.pdf (159.7kB) Uploaded on 03/30/2016 at 03:13PM

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

Attachment(s):

• OHWD Resolution 2015-2016-05.pdf (1.1MB) Uploaded on 03/30/2016 at 03:15PM
• SRCD Resolution 2015-1111.PDF (470.7kB) Uploaded on 03/30/2016 at 03:15PM
• SRCD Resolution 2016-003.pdf (1.2MB) Uploaded on 03/30/2016 at 03:15PM

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):

• SectionD3_DM160317.jpg (3.8MB) Uploaded on 03/31/2016 at 11:10AM

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

Attachment(s):

• Proposed Cosumnes.zip (107.4kB) Uploaded on 03/30/2016 at 06:29PM

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 affected agencies.zip (676.5kB) Uploaded on 03/31/2016 at 11:09AM

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

The California Environmental Quality Act (CEQA) does not apply to this basin boundary modification. By definition, a ?project? subject to CEQA does not include ?[o]rganizational or administrative activities of governments that will not result in direct or indirect physical changes in the environment.? (CEQA Guidelines § 15378(b)(5)). This proposed request would change the mapped boundaries of two subbasins, as those areas are identified in DWR?s Bulletin 118. However, the granting of this request responds purely to an organizational need as local agencies prepare for on-going SGMA compliance. There are no direct or indirect effects to the environment that are reasonably foreseeable from this administrative action. (Public Resources Code §21065.) Both the South American and Cosumnes sub-basins and lands affected by any modification between their boundaries will remain subject to the same SGMA provisions and requirements for sustainable groundwater management regardless of whether DWR does or does not grant the basin boundary modification application. Granting this request would not authorize any change (either direct or indirect) to the physical environment. Furthermore, it is unknown and speculative at this time whether there will even be any physical changes caused by subsequent SGMA compliance in either sub-basin. There is currently not even a final GSA governance structure/framework for either basin, let alone an any adopted or identifiable plan or activity to comply with and implement SGMA in either basin. Even if the proposed basin boundary modification were somehow construed to be a ?project? under CEQA, it would be exempt from CEQA?s substantive provisions for the reasons explained above and under each of the following exemptions: First, there is no possibility of the basin boundary modification causing a significant effect on the environment. (CEQA Guidelines §15061 (b)(3); see e.g., Simi Valley Recreation & Park Dist. v. LAFCO (1975) 51 CalApp.3d 648; City Of Agoura Hills v. LAFCO (9188) 198 Cal,App.3d 480.) Second, the basin boundary modification is an organizational and administrative act of government that will not result in direct or indirect physical changes to the environment. (CEQA Guidelines § 15378 (b)(4); (b)(5).) Third, the basin boundary modification is action by regulatory agencies to assure maintenance of a natural resource, here groundwater. (CEQA Guidelines §15307, 15308.)

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.

As described in DWR Bulletin 118 (DWR, 1974), the Cosumnes Subbasin is defined by the areal extent of unconsolidated to semi-consolidated sedimentary deposits that are bounded on the east by the Sierra Nevada, on the south by the Mokelumne River. West of Highway 99, the boundary of the proposed subbasin follows the Cosumnes River. East of Highway 99, the boundary of the proposed subbasin follows the territorial boundary of Omochumne Hartnell Water District. The northern boundary follows Grant Line Road along the northern boundary of Omochumne-Hartnell Water District and then follows the hydrologic watershed boundary until intersection with the Sierra Nevada. The geologic formations that contain groundwater in the Cosumnes area can be described as follows: 1) The Floodplain Formation (or younger alluvium) is comprised of a recent alluvium deposited along the channel of the Cosumnes River, Deer Creek and Dry Creek (to the south). It consists primarily of unconsolidated silt, fine-to-medium grained sand, and gravel. The floodplain deposits reach a maximum thickness of approximately 100 feet and are quite permeable, yielding a significant amount of water to wells. 2) The older alluvium extends from the ground surface (at the eastern basin boundary) and typically penetrates to a depth of 350 feet in the area at the boundary between the South American and Cosumnes Subbasins, but can extend as deep as 650 feet in the southern part of the Cosumnes Subbasin (WRIME, 2006). The older alluvium is deposited as a sequence of overlapping alluvial fan and terrace systems originating from the Sierra Nevada. It is assigned to the Modesto and Riverbank Formation (Helley and Harwood, 1985), and the Turlock Lake Formations, in order of increasing age (Geoconsultants, Inc., 2016). In the area of interest for this basin boundary change, the formation containing groundwater is the Laguna formation (WRIME, 2011, Figure I-2) which is similar in character to the older alluvial formations (such as the Modesto formation), but overall is finer grained. This formation is geologically heterogeneous in composition (WRIME, 2005; Fleckenstein et al., 2006) with groundwater typically starting 20 ? 100 feet below the ground surface (WaterForum 2006; Underwood 2007). It is commonly used for private domestic wells, and usually does not need treatment (WRIME, 2005). 3) The Mehrten Formation is volcanic in origin and with a range in thickness between 200 and 1,200 feet. The formation has a specific yield of 6 - 12 percent (Olmstead and Davis, 1961). A discontinuous clay layer separates the shallow Modesto Formation from the deeper Mehrten Formation (also referred as Deep Aquifer), but the latter does not receive significant recharge from the Cosumnes River as does the shallow aquifer, nor is as responsive to short term changes in hydrologic conditions or pumping as is the shallower aquifer (WRIME, 2005). The main groundwater body underlying Sacramento County ranges in thickness from several hundred feet in the east, to an estimated 2,000 feet near the Sacramento River (DWR, 1974). This fresh groundwater is underlain by saline water. Page (1973) defined the base of fresh groundwater based on a specific conductance of 3,000 µmhos/cm (micromhos per centimeter), or 2,000 mg/L (milligrams per liter) total dissolved solids (TDS), threshold. Based on this threshold, the depth of freshwater in Sacramento County ranges from an elevation of -800 feet near Sloughhouse in the east, to an elevation of -2,000 feet along the Sacramento River to the west (DWR, 1974).

F. Notice and Consultation

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

? Southeast Sacramento County Agricultural Water Authority (SSCAWA) o Omochumne-Hartnell Water District (OHWD) o Galt Irrigation District o Clay Water District ? City of Galt ? Sloughhouse Resource Conservation District (SRCD) ? Sacramento Central Groundwater Authority (SCGA) o City of Elk Grove o City of Folsom o City of Rancho Cordova o City of Sacramento o County of Sacramento o Sacramento County Water Agency (SCWA) o Florin Resource Conservation District o Omochumne-Hartnell Water District o Rancho Murieta Community Services District o Sacramento Regional County Sanitation District

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

Many of the interested local agencies and public water systems in the affected basins participate in SSCAWA or SCGA and were identified as potentially interested entities, following the guidance provided by Water Code § 10723.2. Additional entities were identified using the Basin Boundary Assessment Tool.

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.

A summary of the various meetings and consultations with other agencies is attached. SRCD and OHWD have and continue to engage in comprehensive and coordinated outreach efforts with other local agencies and stakeholders regarding SGMA compliance and implementation in the Cosumnes Subbasin, which includes discussions of the proposed basin boundary modification. SRCD has sent an outreach letter (See Attachment) to public entities and other stakeholders in the Cosumnes Subbasin. Additionally, both SRCD and OHWD have convened regular and special meetings of their boards of directors that are open to the public, which have provided continual updates regarding this basin boundary modification application and other SGMA implementation issues. Representatives or agents of SCWA, Sacramento County, or SCGA regularly attend such meetings and report back on SRCD?s activities to the Sacramento County, SCWA, and/or SCGA. In response to general concerns raised by those agencies, SRCD and OHWD have engaged SCWA and SCGA staff and officials in directed meetings to address SGMA implementation issues including this basin boundary modification application. Both agencies have voiced concerns to SRCD and OHWD regarding the proposed boundary modification on the grounds that it will adversely affect the previous efforts and understandings developed as part of the Water Forum Agreement, the predecessor effort, and the SCGA groundwater management plan. Neither agency has 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. Neither agency has provided scientific evidence that the existing boundary of the Cosumnes River is the appropriate scientific boundary because, for instance, it acts as some sort of groundwater divide. Similarly, neither agency has explained why 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. SRCD and OHWD recognize and acknowledge the need for ongoing collaborative efforts with SCGA, SCWA, and other local agencies to address basin boundary coordination issues and assumptions as SGMA implementation moves forward.

Attachment(s):

• 2016_3_15 Form Outreach Letter.pdf (545.5kB) Uploaded on 03/31/2016 at 04:49PM
• F.3 Summary of consultations.docx (14.5kB) Uploaded on 03/31/2016 at 04:54PM

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.

The potential for a basin boundary modification was discussed and considered at OHWD Board meetings on the following dates: ? December 3, 2015 ? January 19, 2016 ? February 16, 2016 ? March 15, 2016 ? March 29, 2016 On January 19, 2016, OHWD formally determined that it would explore a potential modification, and prepare a modification request as appropriate. SRCD has discussed and considered issues related to SGMA implementation, including this basin boundary modification, at SRCD board meetings on the following dates: ? April 17, 2015 ? June 24, 2015 ? August 12, 2015 ? November 11, 2015 ? January 13, 2016 ? February 9, 2016 ? March 8, 2016. ? March 29, 2016 SRCD considered and approved this basin boundary modification request at a meeting of its board of directors on November 11, 2015 meeting. The proposed basin boundary modification was also discussed at other affected agencies public meetings. ? October 16, 2015 ? SCGA board meeting directing staff to oppose boundary modifications ? November 4, 2015 - SCGA, directs staff to oppose any change to the Cosumnes River hydrologic boundary ? December 16, 2015 ? SSCAWA meeting the proposed modification was discussed ? December 16, 2015 ? SCGA subcommittee on GSA formation ? January 13, 2016 ? SCGA meeting ? Basin boundary and GSA were discussed ? February 9, 2015 ? SSCAWA meeting the proposed modification was discussed ? February 10, 2016 ? SCGA meeting ? Basin Boundary and GSA were discussed ? February 24, 2016? SSCAWA passed resolution ? as mentioned below The proposed modification, including the scientific and jurisdictional concerns supporting it, was the subject of a joint informational meeting hosted by SRCD and OHWD on March 18, 2016. Following the public outreach process, and in the collaboration directed by the regulations, OHWD and SRCD each convened a special meeting on March 29, 2016 to discuss and formally submit this combined application.

Attachment(s):

• F.4 copies of agendas and notices published.zip (19.8MB) Uploaded on 03/31/2016 at 04:48PM

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.

Attachment(s):

• 03-30-16 Sloughhouse Resource Conservation District.pdf (2.6MB) Uploaded on 03/31/2016 at 04:13PM
• 2016-03-31 Ltr from Sloughhouse Resource Conservation Dist. to Sacrament....pdf (1.1MB) Uploaded on 03/31/2016 at 04:13PM

G. General Existing Groundwater Management

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

Please see attachment in Section G.1

Attachment(s):

• G. General groundwater information_3.30.16.pdf (1.4MB) Uploaded on 03/31/2016 at 10:12AM

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

Please see attachment in Section G.1

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

Please see attachment in Section G.1

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.

Please see attachment in Section G.1

H. Local Support

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

As listed in Section F.4, 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.

Attachment(s):

• OHWD Informational Meeting notice.pdf (244.4kB) Uploaded on 03/31/2016 at 04:29PM
• 2016_3_18 Public Notice of Basin Boundary Modification Public Workshop.pdf (125.2kB) Uploaded on 03/31/2016 at 04:29PM
• 2016_3_30 SRCD mailing list.pdf (87.5kB) Uploaded on 03/31/2016 at 04:29PM
• OHWD Informational hearing mailing list.xlsx (11.9kB) Uploaded on 03/31/2016 at 04:30PM
• SRCD Mailing List_Stakeholders.xlsx (10.8kB) Uploaded on 03/31/2016 at 04:30PM
• Joint meeting presentation attendance_3.18.16.pdf (668.1kB) Uploaded on 03/31/2016 at 04:36PM

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.

SSCAWA adopted a resolution supporting this proposed basin boundary modification request on February 24, 2016 (see attached). At the March 22, 2016 Sacramento County Board of Supervisors meeting, the Board of Supervisors (acting as the legislative body for both SCWA and the County, considered proposed resolutions on groundwater management principles that would, in the case of the County resolution, establish the County?s support for ?maintaining the existing groundwater sub-basin boundaries as established by State Department of Water Resources report Bulletin 118.? A proposed SCWA resolution would have established SCWA?s opposition to any ?basin boundary modification requests within Zone 40 until the request?s science, sustainable management implications, and impacts to the Zone 40 Master Plan, Capital Improvement Plan, and Conjunctive Use program are discussed, understood, and coordinated with all interested stakeholders.? Both SRCD and OHWD submitted formal comment letters on these proposed resolutions, emphasizing the need for additional discussion and collaboration, and requesting additional discourse with the County and SCWA regarding their specific concerns on the basin boundary application before either agency took a formal position opposing the change (the concerns raised at the March 22 meeting, and leading up to it, focused generally on a desire to maintain the existing boundaries and management structure, without additional elaboration). In response to those comments, discussion and action on the proposed resolutions were continued to a later date. OHWD agreed to provide the final version of this Basin Boundary Modification Request to the SCWA, SCGA and the Board of Supervisors upon filing, and expressed its continued commitment to working with those agencies and other area stakeholders to resolve any issues and to identify the most efficient and sustainable solution for the basins. SCGA has expressed informal concerns about the proposed modification?s impact on SCGA?s existing management structure, and in particular that agency?s ability to successfully submit a SGMA-compliant alternative plan under the new Groundwater Sustainability Plan regulations. OHWD and SRCD have engaged with SCGA on these concerns, and requested additional details regarding SCGA?s particular concerns, in the hope of resolving them. On March 30, 2016, SCWA submitted written material (See Section F.5) to SRCD generally opposing the basin boundary modification application and urging that its submission be delayed until various inter-basin coordination ?questions can be answered to the satisfaction of all impacted stakeholders.? The SCWA letter provided a better articulation of concerns than the agency had previously voiced, but it still remained generalized and posed technical questions and issues that SRCD and OHWD believe are not relevant to the application at hand, but rather raise broader inter-basin coordination issues that will have to be addressed as SGMA implementation proceeds regardless of the outcome of this application. SRCD provided a response to SCWA?s recent letter (See Section F.5) that further addressed this and other specific issues.

Attachment(s):

• SSCAWA OWHDboundchangeresolution.pdf (738.2kB) Uploaded on 03/31/2016 at 04:35PM

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

OHWD and SRCD remain committed to identifying a long-term, workable solution for SGMA compliance in this region, and hope to work collaboratively with SCWA and SCGA regarding any concerns created by this application. In a letter dated March 30, 2016 SCWA articulated some concerns and technical questions regarding the proposed basin boundary modification. By letter the next day SRCD provided a response that is included in Section F.5 of this application. The full text of the March 31, 2016 response letter should be reviewed for necessary details, but the general points of the SRCD letter were as follows: ? Many Bulletin 118 Basin Boundaries Have Been and Are Continually Adjusted For Jurisdictional and Scientific Reasons ? DWR Created the March 31, 2016 Deadline for Basin Boundary Modification Applications Under SGMA ? The District Believes Prompt Determination of the Appropriate SGMA Basin Boundary is the More Reasonable and Practical Approach So That the Playing Field (if you will) is Established Before Further SGMA Implementation Efforts and Resources are Expended ? The County?s Past Groundwater Management Efforts Did Not Adhere to the Bulletin 118 Basin Boundary You Now Advocate For And Did Not Adequately Consider the Cosumnes Subbasin or SGMA Compliance ? Assumptions Regarding The Sustainable Yield of Either the South American or Cosumnes Subbasins and Boundary Interface Issues Are More Appropriately Addressed During SGMA Implementation As Necessary Inter-Basin Coordination Issues ? SGMA is a Groundbreaking Law That Requires the Creation of New Governance Structures or at least a Significant Re-Evaluation of Current Efforts ? Neither the District?s Basin Boundary Modification Application Nor Its GSA Elections Will Impede Progress On An Acceptable Alternative Plan for the South American Basin Impede Progress 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. 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). To the extent that the previous discussions with SCGA and SCWA materialize into formal opposition resolutions or additional comments on this application, OHWD and SRCD remain committed to engaging with those agencies to resolve any issues and respond to the particular concerns of those agencies (and any other stakeholders) in careful detail. Furthermore and regardless of the outcome of this basin boundary application, SRCD and OHWD recognize and acknowledge the need for ongoing collaborative efforts with SCGA, SCWA, and other local agencies to address basin boundary coordination issues and assumptions as SGMA implementation moves forward.

Attachment(s):

• Final OHWD_SRCD_CityCountyResponse_05252016.pdf (231.4kB) Uploaded on 05/25/2016 at 10:21AM
• PecciWheat_Response_05232016.pdf (150.7kB) Uploaded on 05/23/2016 at 04:44PM

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.

See attached

Attachment(s):

• I. Hydrogeologic conceptual model _03.30.16.pdf (1.5MB) Uploaded on 03/31/2016 at 09:17AM

K. Technical Studies for Internal Scientific Modifications

1. A qualified map depicting structural geologic features that could significant impact or impede lateral groundwater flow.

No new geological map has been developed. ? Title:Geologic map of the Sacramento quadrangle, California, 1:250,000 ? Author(s): Wagner, D.L., Jennings, C.W., Bedrossian, T.L., and Bortugno, E.J. ? Publishing Organization: California Division of Mines and Geology ? Series and Number: Regional Geologic Map 1A ? Publication Date: 1981 ? Map Scale: 1:250,000 ? http://ngmdb.usgs.gov/Prodesc/proddesc_520.htm

Attachment(s):

• USGS Map with boundaries.jpg (12.8MB) Uploaded on 03/31/2016 at 01:11PM

2. Geologic and hydrologic evidence of groundwater conditions by attaching or providing a URL to any of the following:
   1. Historical and current potentiometric surface maps, groundwater levels, groundwater recharge and discharge areas of the aquifer system within the vicinity of the proposed boundary modification.
   2. Aquifer performance testing results demonstrating basin boundary condition response.
   3. Water quality information of the aquifer system including but not limited to general water quality parameters and isotopic analysis.
   4. Supporting certified geophysical studies.
   5. Any other pertinent information.

Please see attached.

Attachment(s):

• 1717-01 Final Report.pdf (2.3MB) Uploaded on 03/31/2016 at 11:31AM
• K. Technical Studies for science modification_03.30.16.pdf (3.9MB) Uploaded on 03/30/2016 at 05:08PM

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):

• SOUTH_BASIN_GMP_FINAL_2011.pdf (12.3MB) Uploaded on 03/31/2016 at 09:27AM
• CSCGMP_final.pdf (11.3MB) Uploaded on 03/31/2016 at 09:27AM
• SSCAWA_GMP_2002.pdf (35.5MB) Uploaded on 03/31/2016 at 09:32AM

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

As described in Section G of this proposed modification submittal, Sloughhouse Resource Conservation District (SRCD), and Omochumne-Hartnell Water District (OHWD) as an individual water district or as a representative of one of the three members of the Southeast Sacramento County Agricultural Water Authority (SSCAWA) have participated in numerous historical groundwater management projects and helped implement them for the benefit of the Cosumnes River and its underlying groundwater basins. OHWD and SRCD are also involved in multiple existing management projects, and are working toward implementation of new management projects. The first step towards achieving compliance under SGMA for any groundwater sub-basin is the establishment of one or more Groundwater Sustainability Agencies (GSAs) to govern groundwater management for that basin. The separate member entities within the Cosumnes Subbasin plan to establish multiple GSAs which will coordinate with each other through a formal agreement to form a single GSP for the Cosumnes Subbasin. OHWD and SRCD have each held hearings on their respective GSA status, and have each elected to serve as GSAs for all or a portion of their service areas. (Attachments L.2). As of the date of this submittal, no other entity has conducted a hearing or submitted a Notice of Intent to serve as a GSA in this region. OHWD and SSCAWA are reaching out to the remaining public agencies within the Cosumnes Subbasin who are not members of SSCAWA (e .g., City of Galt, RD 800, Sloughhouse RCD, SMUD, County of Sacramento) to form a group where planning and implementation of SGMA can occur between the member agencies.

Attachment(s):

• L.2 OHWD Resolution 15-16_06.pdf (992.7kB) Uploaded on 03/31/2016 at 09:31AM
• L.2 SRCD Resolution 2016_1.pdf (1.5MB) Uploaded on 03/31/2016 at 09:32AM