UPDATE 11/16/22: FACTS AND FLAWS: The Indian Wells Valley Groundwater Sustainability Plan
April 1, 2022
Executive Summary
This Page will be updated on an ongoing basis as needed. It is intended to assist the Groundwater Authority in promoting public awareness while giving Stakeholders, property owners and public officials a resource for future planning considerations. All data is deemed to be accurate and comes from the GSP, Annual Reports for Water Years 2019-2020-2021 and the Determination Letter and Corrective Actions issued by the Department of Water Resources on January 13, 2022.
UPDATES
Update: DWR Portal – Groundwater Management page for the 2021 Water Year Annual Report is here.
Update 4/18/2022: IWVGA Meeting video, Water Manager’s Report by Stetson Engineers (Below)
Update 5/28/2022: Added DWR’s SGMA-GSP Facilitation page, sponsored by the IWV Water District.
Update 11/16/2022: AVEK Pipeline Project Alignment Study Presentation by Provost & Pritchard
Department of Water and Power – Determination Letter Excerpts
On January 13th, 2022, the California Department of Water and Power issued a Determination Letter approving the Indian Wells Valley Groundwater Sustainability Plan (GSP) prepared by the Indian Wells Valley Groundwater Authority (IWVGA)
The IWVGA is the sole Groundwater Sustainability Agency (GSA) for the IWV Groundwater Basin and is responsible for complying with SGMA requirements, including the preparation and implementation of the Groundwater Sustainability Plan (GSP). The GSP was Prepared by Stetson Engineers and dated January 2020. The GSP was adopted by the IWVGA Board of Directors on January 16th, 2020 and was submitted to DWR on January 31st, 2020.
The Department strongly encourages the recommended corrective actions be given due consideration and suggests incorporating all resulting changes to the GSP in future updates.
Department of Water Resources staff note that the Plan does not propose to end overdraft during the initial twenty-year Plan period or the fifty-year planning horizon and that, even with full implementation of the proposed projects and management actions, the Basin would be subject to perpetual overdraft, albeit at a reduced rate relative to current conditions.
Department staff regard this to be a flaw with the Plan, but one the Authority should be able to address in a timely manner and not one that would interfere with the near-term implementation of the current Plan or, if promptly corrected, undermine long-term efforts to achieve sustainable groundwater management for the Basin.
However, the Plan acknowledges that the imported water supply project, in particular, which the Authority regards as being instrumental to meeting its sustainability goal, requires the securing of funds and formalizing agreements with third parties that are beyond its control.
Update the Plan to include projects and management actions sufficient to eliminate perpetual overdraft currently projected beyond the fifty-year planning and implementation horizon. Include contingency elements that would be triggered if water budget inflows are not increased over the rolling fifty-year planning and implementation horizon, particularly if imported water sources are not available.
The contingency plan should include additional projects and management actions that may be implemented to achieve the sustainability goal for the Basin within and beyond the twenty-year timeframe of SGMA, in the event that the Authority is unable to implement projects and management actions described in the Plan or that those projects and management actions fail to produce the anticipated results.
Adjudication Lawsuit – Excerpt from Indian Wells Valley Water District
As for litigation, there are multiple lawsuits filed with the court. Mojave Pistachios and Searles Valley Minerals have filed separate but similar lawsuits referred to as reverse validation actions against the Authority challenging the GSP and related implementation actions, including the Replenishment Fee. These lawsuits are currently pending in Orange County. The Water District is a party to the reverse validation actions. In addition to the two reverse validation actions, Mojave Pistachio filed a complaint against the Water District, Searles Valley Minerals, and Meadowbrook Dairy requesting a “limited physical solution” between only these four major water producers. The Navy was not named in the lawsuit.
Most recently, the Water District’s Board of Directors voted to file a Comprehensive Adjudication that does include Navy participation and allows all those who may claim a right to pump or store water in the basin to participate, assert and prove any rights they may claim. A case management conference has been set by the Court for March 15, 2022.
Stetson Engineers – Water Manager Report, IWVGA Meeting April 13, 2022 (Video begins at 43:50)
Amendments to the Indian Wells Valley Groundwater Sustainability Plan are Necessary
Department of Water Resources – January 13, 2022
The Plan should be amended to include an updated and detailed timetable for the adoption and implementation of current projects and management actions, as well as an explanation of when and under what circumstances the Authority would implement alternative or additional projects and management actions, as needed.
Conclusions
- The GSP lacks critical Water Budget data and scientific validation from outside sources.
- The GSP is fundamentally outdated based on current key data points including Annual Pumping and Recharge.
- The Average Annual Change to Groundwater Storage is -5,546. Therefore, the actual Mountain Front Recharge for the Indian Wells Valley Groundwater Basin is 21,229 Acre Feet per year, not 7,650.
- If a TAC challenge of Evapotranspiration is successful, the Change to Groundwater in Storage is -1,066 AF/yr.
- The “AVEK” project to import water from the State Water Project together with an Interconnect in California City is unnecessary and infeasible. Water rights have not been purchased.
- Corrective Action 4 Items 1-4 are noted with emphasis added
- Update and Include a Contingency Plan with Additional Projects and Management Actions.
- The Plan should be Amended.
- Provide updates on negotiations and feasibility of imported water supplies.
- GA reported that imported water was not to have been pursued in the WY20 Annual Report.
Key Findings
- Information contained herein is derived from the IWV GSP, Annual Reports for water years 2019-2021 and the Determination Letter from the Department of Water Resources.
- Flaws in data collection derive from both the definition of the IWV “Basin” as well as the lack of monitoring wells and/or modeling for a large portion of the Indian Wells Valley Watershed Basin.
- In addition, the Indian Wells Valley “Watershed Basin” includes the sub-basins of Rose Valley and Coso/Argus. The GSP refers to the “Basin” which is also called the “Management Area”.
- The GSP overestimated Annual Pumping by over 12,000 acre feet per year.
- The GSP used the lowest of any prior study in attempting to determine the Annual Recharge (Todd) when other studies have determined the Annual Recharge to be 11,000 to 12,000 Acre Feet per year or more. (cit.)
- The IWVGA Recycled Water Project and City of Ridgecrest have been unable to secure an industrial user/buyer for treated Wastewater beyond current uses.
- A tertiary treatment component to the WWTF is not part of currently planned construction scheduled to begin in 2023 with completion in 2025.
- The IWVGA failed to secure funding for a buy-in to the State’s water “futures” market.
- The IWVGA is currently embroiled in a number of lawsuits which may take years to resolve.
- The IWVGA Fee currently assessed to Indian Wells Valley water users is unsubstantiated and unwarranted.
To the Editor: An open letter to the Directors of the IWV GA by Nick Panzer, February 4, 2022, The News Review
California recently approved our Groundwater Sustainability Plan contingent upon our amending it before 2025 to correct seven deficiencies. The most significant of those deficiencies is reliance upon a water import project without a backup plan that relies solely on local water sources. The state requires a backup plan in case importing proves infeasible or incapable of producing the sustainable result required by law.
A backup plan will require a determination of rights to local groundwater, something that only a state court can determine through a process known as Adjudication. In making that determination, the state court itself must comply with California groundwater sustainability law. I encourage you to embrace Adjudication as an opportunity to address the above noted deficiencies and bring our Groundwater Sustainability Plan into full compliance with state law.
Index
Index items are #Jump links to Sections below. Red Alerts #Jump to the noted DWR Correction Action.
- Key Numbers – Indian Wells Valley Groundwater Basin (Current)
- Annual Pumping – Indian Wells Valley Groundwater Basin
- Annual Recharge – Mountain Front Recharge Zones
- Recycled Water – 2019-2021 (Recycled treated as Outflow)
- Current Water Budget
- Annual Groundwater Storage Change
- Recharge Calculations
- Historical Water Budget (1922-2016)
- Current Water Budget (2011-2015)
- Data Gaps
- Undesirable Results
- Project 1: Imported Water Project
- Project 2: Recycle Water Project
- Evapotranspiration (ET)
- Management Area – Watershed Basin (Maps)
- Adjudication Resets Calculation and Distribution of IWVGA Fees
- Proposed Projects
- Timelines
- Downloadable GSP Files and Annual Reports 2019-2021
- March 9, 2022 Meeting Video – Annual Report Presentation (Stetson)
Department staff recommend approval of the Plan subject to recommended Corrective Actions.
- Provide Information on Communications with Stakeholders, Community Engagement Plan
- Define the Connectivity of Three Hydrogeologic Zones, Fill Data Gaps
- Explain Water Budget Elements, Predict Recharge from Projects
- Update and Include a Contingency Plan with Additional Projects and Management Actions
- Identify Conditions Producing Undesirable Results, Minimum Thresholds
- Designate Representative Well Monitoring Locations
- Update Data Management System, Include Rationale for Updating Management Area Boundaries
Key Numbers – Indian Wells Valley Groundwater Basin (Current)
| Data Category | Acre Feet/year | Confidence Level |
| Annual Pumping | 20,800 | High |
| Annual Recharge | 7,650 | Low |
| Recycled Water (Treated for Industrial Use) | 2,000 | Medium |
| Evapotranspiration | Unknown | Low |
| Change of Groundwater in Storage | Unknown | Medium-Low (Theissen Polygon) |
| Current Water Budget | Unknown | None |
Annual Pumping – Indian Wells Valley Groundwater Basin
DWR Pages 3-4 of 45: According to the Plan, overdraft has been documented in the Basin since at least the 1960s and represents a significant barrier to sustainability. The Plan describes the total inflow into the Basin as 7,650 acre-feet per year and the current outflow (for the years 2011-2015) as 32,640 acre-feet per year, representing an overdraft rate of over 400 percent.
| Water Year Total Estimated Pumping (AF) | |
| GSP (Estimated 2011-2015) | 32,640 |
| WY 2019 | 22,800 |
| WY 2020 | 21,990 |
| WY 2021 Final Table 6-2 | 20,800 |
| Water Use Sector | Estimated No Action Projections (AF) | WY 2021 Reported Pumping (incomplete)3 | WY 2021 Total Estimated Pumping 6 |
| Urban | 6,940 | 6,530 | 6,530 |
| Industrial | 2,910 | 2,180 | 2,180 |
| Agriculture | 21,630 2 | 8,820 | 8,900 |
| Other – Federal 1 | 2,040 | 1,436 | 1770 4 |
| Other – Domestic/ Mutuals/Co-Ops | 1,380 | 430 | 1,420 5 |
| TOTAL | 34,900 | (incomplete) | 20,800* |
1 Federal groundwater use is for NAWS China Lake and are provided by the U.S. Navy.
2 This value includes planned agricultural projects provided by pumpers and probably overestimates future agricultural groundwater production.
3 These values underestimate actual groundwater production in WY 2021 because not all non-de minimis groundwater producers submit data regularly to the IWVGA and because some groundwater producers were not required to report their groundwater production during WY 2021.
4 Federal entities are not required to report monthly production to the IWVGA for the purpose of the fee.
5 De minimis users (those that produce less than 2 acre-feet per year (AFY) or those that have four or fewer connections) are not required to report monthly production to the IWVGA for the purpose of the fee.
6 See Attachment H for a more detailed table.
Annual Recharge – Mountain Front Recharge Zones
Limited aquifer property data was used to calibrate the groundwater model. Data gaps for aquifer properties include the El Paso area, northwest, southwest, and southeast areas of the Basin. In addition, the definable bottom of the Basin is a current data gap. It will be evaluated whether deep drilling or more recent geophysical data will provide the necessary data to fill this data gap.
The recharge zones identified by DRI are shown in Figure 3-11. The total area of recharge is about 770 square miles. The area and estimated annual recharge in each zone are shown in Table 3-3.
| Table 3-3 Recharge Zone | Area (sq miles) | Annual Recharge |
| Rose Valley* | 193 | 2,400 |
| Sierra Nevada N. | 116 | 2,100 |
| Sierra Nevada S. | 101 | 1,500 |
| El Paso | 56 | 50 |
| Argus and Coso | 302 | 1,600 |
| TOTAL | 768 | 7,650 |
DRI – Desert Research Institute (Navy provided model)
We can no longer ignore the evidence of known local water availability. Pat Farris, Publisher of The News Review, August 8, 2021
I quote Dr. Austin from an interview, published in the News Review October 30, 1981 regarding groundwater bearing granitic rock. Noteworthy is the fact that Austin did not gain his knowledge of the ground water in this valley by building a model as most scientists do. He was an explorationist, gaining his knowledge by drilling and exploring. – Pat Farris
“If you assume that the Sierra granitic had only two percent fracture pore face, which is a very conservative estimate, there is three cubic miles of water in that rock. We have done some drilling of granitic’s alongside Rose Valley* and we came out with close to ten percent pore face. That was a 4,000 ft plus hole. If the Sierra granitic’s have 10 percent pore face, you’re talking 51 million feet of water, in the fractures alone in the Sierra Nevada. If it were only two percent, you’re still looking at 10 million feet. Ten times what is in the upper floor of this valley naturally. That is all water that will ultimately run into this valley. That is the buffer that protects us in the dry years and the wet years. Because it moves slowly and steadily through the years in the underground into valley with that current estimated recharge into the valley, it would take us 2,500 years to deplete that storage above the valley floor. There is a lot of water stored out there beside us… 15 cubic miles, possibly.” – Dr. Carl Austin
See Corrective Action 2 – Define the Connectivity of Three Hydrogeologic Zones, Fill Data Gaps
Recycled Water 2019-2021 (Recycled treated as Outflow)
Total water use in the IWVGB during WY 2020 is comprised of groundwater supplies and recycled water supplies. See Chapters 6.1 and 6.2 above for additional detail on these supplies.
| 2019 | 2020 | 2021 | ||
| Annual Pumping | 22,800 | 21,990 | 20,800 | |
| Golf Course 2 | 350 | 480 | 400 | |
| Alfalfa fields 3 | 130 | 110 | 110 | |
| Other (40% Discharge to Ponds? 4 | 800 | 740 | 790 | |
| Total Recycle Used | 1,280 | 1,330 | 1,300 | |
| Recycled Discharged to Ponds with 60% Evaporation 5 | 2,110 | 1,860 | 1980 | |
| Total Outflow Plus Recycled Used | 24,080 | 23,330 | 22,100* |
1 Data provided in email by the City of Ridgecrest
2 Used for irrigation of golf course on NAWS China Lake.
3 Used for irrigation of alfalfa fields for beneficial re-use.
4 Recycled water not used for urban and agricultural irrigation is disposed of in
evaporation/percolation ponds.
5 It is estimated approximately 60 percent of the recycled water discharged to the ponds evaporates, with the remaining percolating to the groundwater (Provost and Pritchard Consulting Group, 2015). In addition, these ponds partially support the Mojave Tui Chub habitat on NAWS China Lake.
See Corrective Action 3: Explain Water Budget Elements, Predict Recharge from Projects
Current Water Budget – Change to Groundwater in Storage
| 1922-2016 Historical Water Budget | 2011-2015 Averaged Current Water Budget | 2019 WY Annual Report (See Chart Below) | 2020 WY Annual Report | 2021 WY Annual Report | |
| Mountain Front Recharge | 7,650 | 7.650 | 7,650 | 7,650 | 7,650 |
| Total Inflow | 7,650 | 7,650 | 7,650 | 7,650 | 7,650 |
| Evapo-transpiration (ET) | 6,580 | 4,850 | (incomplete) | ? | |
| Inter-basin Subsurface Flow | 60 | 50 | (incomplete) | 200? verify | |
| Groundwater Extractions | 15,240 | 27,740 | 22,810 1 | 21,990 | 20,800 |
| Total Outflow | 21,880 | 32,640 | 24,090 2 | 23,320 | 22,100 |
| Recycled Water Used | 1,280 | 1,330 | 1,300 | ||
| Change to Groundwater in Storage | -14,230 | -24,990 | –10,450 2 | No Data 3 | No Data 4 |
1 2019 Annual Report – Table 6-1: IWVGB Groundwater Production Estimates
2 2019 Annual Report – The estimated groundwater storage change in the main basin of the IWVGB during WY 2019 is a loss of 10,450 acre-feet (AF). Total water use in the IWVGB in WY 2019 is estimated to be 24,090 AF which includes both groundwater production and recycled water reuse.
3 2020 Annual Report – Stetson response to comments (Page 1 of 12) Given the limited data for spring 2020, estimates of WY 2020 changes of groundwater in storage will not be included in future Annual Reports.
4 2021 Annual Report – Stetson in process 3/31/22 unavailable for 2021 report year.
GA Board disagree on basin overdraft The News Review, March 18, 2022
- “I urge all GA Board members to focus on understanding the actual extent of the basin problem before spending massive amounts of money without a clear vision or sound objectives” said James Mower, President of the Ridgecrest Area Association of Realtors.
Johnson clarifies IWV Groundwater annual report – The News Review May 28, 2021.
- “The 2020 Water Year Annual Report was sent to the state’s Department of Water Resources prior to being heard and approved by the GA board or its committees.”
- “The annual report was not run through the Technical Advisory Committee,” said Don Decker, who serves as a TAC member, “an example of a failure really to properly utilize the available resources.”
- Stetson mentioned that COVID-related difficulties made data collection for the 2020 and 2021 years more difficult. But stakeholders questioned the validity of the reported inconsistencies.
Rajtora: we can’t control overdraft until we understand it – The News Review, March 25, 2022
- “We cannot be expected to control our overdraft until we understand our overdraft,” said GA representative Stan Rajtora of the IWV Water District.
- “There’s no question that a huge amount of work went into the report, but I’ve never seen a report that has so many missing pieces,” said Don Decker, who serves on the GA’s Technical Advisory Committee.
- “Some have been offered as a COVID issue, but the fields required for depth measurement are out in the open … two years in a row is inexcusable in my humble estimation.”
See Corrective Action 2 – Define the Connectivity of Three Hydrogeologic Zones, Fill Data Gaps
See Corrective Action 3: Explain Water Budget Elements, Predict Recharge from Projects
5.3 Estimated Change to Groundwater Storage
5.3.2 Thiessen Polygon Method (Under Review during WY 2022)
The current (2021) groundwater monitoring program (GWMP) utilizes 177 wells for biannual groundwater level measurements (Attachment E). The GWMP has been refined since 2015 as new monitoring wells have been added to fill in data gaps within the basin, and wells without access have been removed from the GWMP. KCWA, Navy, and Stetson jointly measure depths to water at the wells in the GWMP each year during one week in October, and one week in March. Due to ongoing COVID-19 restrictions during Spring 2021 groundwater level measurements, groundwater levels were only measured at 113 (64%) of the current GWMP wells. Most of the 64 un-measured monitoring wells in Spring 2021 were domestic wells near the pumping centers within the basin (Figure 5-2 denoted as small blue dots).
Given the partial data available during the last two years, this WY 2021 Annual Report is limited to the changes in groundwater levels observed between 2015 and 2021 for the discussion of storage change. Current groundwater datasets are considered insufficient for estimating the total change of groundwater in storage for WY 2021.
In previous annual reports, the Thiessen Polygon Method was used to estimate changes in groundwater storage. Comments were received from members of the Technical Advisory Committee (TAC) and the IWVGA Board requesting more clarity on this method and comparison to the existing numerical groundwater model’s calculations for the GSP. Given the importance of this evaluation and quantification of changes of groundwater in storage, the IWVGA Water Resources Manager is proposing a TAC review of the data and methodology to establish the best method to assess the basin. This work is anticipated to be completed during WY 2022 and reported in the next annual report.
*Using the last available data including the El Paso Subarea, the Theissen Polygon Method indicates the Average Annual Change to Groundwater Storage is 5,546 acre-feet per year for the years 2016-2019.
| Polygon Region | Acres | 2016 Below N | 2017 AboveN | 2018 Below N | 2019 Wet Year | 2020 No Data | Total 2016-2019 | Average 2016-2019 | 2021 No Data |
|---|---|---|---|---|---|---|---|---|---|
| Northwest | 45,359 | 774 | -7,309 | -4,951 | -8,732 | invalid | -20,220 | -5,055 | invalid |
| Southwest | 6,549 | -601 | -2,530 | -1,124 | -2,516 | invalid | -1,740 | -435 | invalid |
| Southeast | 37,365 | -1,448 | -1,220 | -3,176 | -2,221 | invalid | -8,070 | -2,017 | invalid |
| Navy | 128,815 | -2,041 | 5,132 | -10,131 | -2,021 | invalid | -9,060 | -2,265 | invalid |
| Subtotal Basin | 238,088 | -3,316 | -5,927 | -19,382 | -10,459 | -39,090 | -9,772 | ||
| El Paso Subarea | 66,638 | 4,702 | 4,432 | -2,554 | 10,326 | invalid | 16,906 | 4,226 | invalid |
| Main Basin | 304,726 | 1,387 | -1,495 | -21,936 | -133 | -22,184 | -5,546* | ||
| Rose Valley Subarea | |||||||||
| Main Basin Plus El Paso and Rose Valley |
Recharge Calculations
*The Average Annual Change to Groundwater Storage is -5,546. Therefore, the actual Mountain Front Recharge for the Indian Wells Valley Groundwater Basin is 21,229 Acre Feet per year (3 year average). If a TAC challenge of Evapotranspiration is successful, the Change to Groundwater in Storage is -1,066 AF/yr.
| Submitted GSP 2011-2015 Average Estimate Table 3-7 | 1922-2016 Table 3-6 | Actual 2019-2021 5 | Include Challenge to Evapotranspiration 6 | |
| Mountain front Recharge | 7,650 1 | 7,650 | 21,229 | 21,859 |
| Total Inflows | 7,650 | 7,650 | 21,229 | 21,859 |
| Evapotranspiration | 4,850 | 6,580 | 4,850 | 1,000 4 |
| Inter-basin Subsurface | 50 | 60 | 200 3 | 200 |
| Annual Pumping | 27,740 | 15,240 | 21,725 2 | 21,725 |
| Total Outflows | 32,640 | 21,880 | 26,775 | 22,925 |
| Change to Groundwater in Storage | -24,990 | -14,230 | -5,546 | -1,066 |
1 GSP Annual Recharge (Mountain Front Recharge) = 7,650
2 Annual Pumping WY 2019-2021 Three-year Average (Annual Reports Actual) = 21,725
3 Subsurface Outflow = 200. Why did it increase?
4 Evapotranspiration has been challenged by TAC member Don Decker, estimating it’s closer to 1,000 AF/yr.
Recharge Calculation Chart – GSP in Red, 2019-2021 Average in Blue
Calculations:
Change to Groundwater in Storage = Inflows – Outflows
Change to Groundwater in Storage = Mountain Front Recharge MINUS (ET + Subsurface outflows + Annual Pumping)
OR
5 Mountain Front Recharge = Change to Groundwater in Storage PLUS (ET + Subsurface outflows + Annual Pumping)
Mountain Front Recharge = -5,546 + (4850 + 200 + 21,725)
Mountain Front Recharge = 21,229
OR
6 Challenge Evapotranspiration (20% of estimate per Don Decker-TAC)
Mountain Front Recharge = -1,066 + (1,000 + 200 + 21,725)
Mountain Front Recharge = 21,859
See Corrective Action 3: Explain Water Budget Elements, Predict Recharge from Projects
See Corrective Action 6: Designate Representative Well Monitoring Locations
Historical Water Budget (1922-2016)
Current Water Budget (2011-2015 Average)
See Corrective Action 3: Explain Water Budget Elements, Predict Recharge from Projects
Data Gaps – 2021 WY Annual Report
IWVGA 2021 WY Annual Report Chapter 7, Other Data Collection and Basin Management Tasks:
In WY 2021, the IWVGA has continued its data collection efforts and basin management tasks to improve Basin understanding and monitor groundwater sustainability, in addition to the regular groundwater level monitoring discussed in Chapter 5. These efforts help address the data gaps outline in the GSP and are listed below:
- Data gaps associated with groundwater monitoring in the El Paso subarea
- Data gaps associated with streamflow and mountain front recharge
- Data gaps associated with domestic wells data and subsequent water usage
- Data gaps associated with the subsurface flow from Rose Valley
- Data gaps associated with the subsurface flow to Salt Wells Valley
- Data gaps associated with groundwater dependent ecosystems (GDEs)
- Data gaps associated with aquifer properties
GSP Page 6-8, 6.4.2 Periodic Evaluations and Assessments: Monitoring Network and Data Gaps: A description of the monitoring network will be provided. Data gaps that have been identified and efforts to fill those gaps will be described. An assessment of the effectiveness of the monitoring programs will be provided, along with a schedule to address the data gaps.
Lastly, the Department’s review and approval of the Plan is a continual process. Both SGMA and the GSP Regulations require the Department to periodically review the Plan and its implementation. 25 The Department’s periodic reviews will assess changed circumstances that could render the Plan inadequate and evaluate the progress toward achieving the sustainability goal for the basin. (Page 10 of 45)
“I’ve never seen a Report that has a many missing pieces as the 2021 Annual Report. Two years in a row is inexcusable. It produces a data gap that cannot be recovered.” – Don Decker, TAC member, March 9, 2022
See Corrective Action 2 – Define the Connectivity of Three Hydrogeologic Zones, Fill Data Gaps
Undesirable Results
DWR Page 4 of 45: As required by SGMA and the GSP Regulations, the Authority adopted a Plan to define a sustainability goal for the Basin. The Plan also prescribes how the Authority would meet the goal within the twenty-year sustainability timeframe and maintain the goal over the fifty-year planning and implementation horizon. The Authority defined the sustainability goal for the Basin as to “[m]anage and preserve the [Basin] groundwater resource as a sustainable water supply. To the greatest extent possible, the goal is to preserve the character of the community, preserve the quality of life of the [Indian Wells Valley] residents, and sustain the mission at NAWS China Lake.”
IWVGA misunderstands basics of SGMA The News Review, Op-ed by Nick Panzer, former PAC member, March 11, 2022
IWVGA threatens to push local ag out of business The News Review Op-ed by Kelly Garman, February 18, 2022
- “This GSP is radically different from those proposed in the Southern San Joaquin Valley,” said Rod Stiefvater, owner of Mojave Pistachios. “The Plan sets a dangerous precedent that could extend into other basins across the state by setting water allocations based upon a GSA’s determination of water rights.”
- “DWR failed to safeguard agriculture and the intent of SGMA when they approved the Authority’s Groundwater Sustainability Plan,” continued Stiefvater. “The Authority has been fiscally irresponsible and has misrepresented many facts and conditions to the residents of the Indian Wells Valley. We intend to fight this lawsuit and we now believe we have standing to pursue our existing litigation against the authority and secure our water rights.”
No water Shut-off for Searles Valley Minerals Daily Independent, September 22, 2021
- “If you cut off the water supply to Searles, two things will happen. One is Searles will go out of business,” said Jeff Dunn, special counsel to SVM. “And if it goes out of business it will never be able to pay your replenishment assessment.”
- The second result, according to Dunn, is the loss of water for Searles Water Company’s domestic customers. “This type of action, which is just putting a gun to the head of Searles and the communities that depend upon it, is unprecedented,” Dunn said.
See Corrective Action 5: Identify Conditions Producinag Undesirable Results, Minimum Thresholds
Project 1: Imported Water Project (Antelope Valley East Kern-AVEK Project)
Final Report: (AVEK Project not included)
3.1.2 Project 1: Develop Imported Water Supply
Due to overdraft conditions in the Indian Wells Valley and anticipated future water demands in excess of the Basin sustainable yield, securing imported water supplies is a priority for the Basin. The IWVGA has retained Capitol Core Group, Inc (Capitol Core) for the following general tasks:
- Identify and Procure Imported Water Supplies
- Develop and Secure Transfer Partners
- Identify and Secure Funding Sources
During WY 2021, the IWVGA Board of Directors amended the IWVGA Agreement with Capitol Core to extend the term of the agreement through December 31, 2021 and approved a 2021 Scope of Work.
(Pipeline “interconnect” from California City to Ridgecrest plus imported water from The California State Water Project or other water rights holders.)
DWR: However, the Plan acknowledges that the imported water supply project, in particular, which the Authority regards as being instrumental to meeting its sustainability goal, requires the securing of funds and formalizing agreements with third parties that are beyond its control. In addition, as discussed extensively above, even with full implementation of all projects, the current Plan does not anticipate the elimination of groundwater overdraft at any time, although the rate of overdraft could be dramatically reduced in the short term with successful implementation of existing projects and management actions. For these reasons, Department staff recommend corrective actions that will bring greater specificity and certainty to the planning process and introduce alternative projects and management actions that the Authority may implement if the preferred options are found to be infeasible (See Recommended Corrective Action 4).
- State Water Project new “futures” market, poor reviews and no water, big players corrupting market (citations) Cost plus annual maintenance (See GSP Project Cost)
- Uncertainty, financial and economic conditions, cost-benefit analysis, money utilized elsewhere? IWVGA fees and basis will be recalculated in the Adjudication.
- GSP is inconsistent with SGMA’s primary Policy Statement
See Corrective Action 3: Explain Water Budget Elements, Predict Recharge from Projects
Project 2: Recycle Water Project
3.1.3 Project 2: Optimize Recycled Water 2020
The IWVGA, in coordination with the City of Ridgecrest, began development of its recycled water program to optimize the use of recycled water from the City of Ridgecrest’s wastewater treatment facility. The purpose of the program is increase local water supply, decrease dependence on imported water, and increase the sustainable yield of the IWVGB. During WY 2020, initial program development and coordination efforts between the IWVGA and the City of Ridgecrest took place.
3.1.3 Project 2: Optimize Recycled Water 2021
The IWVGA Board of Directors adopted Resolution Number 02-20 on November 19, 2020. This Resolution formally created the Recycled Water Program. The IWVGA provided large permanent users of groundwater with the opportunity to participate in the Program.
Participants would fund the cost of developing the final Recycled Water project, including producing facility designs for the recycled water system. In exchange for the funding, participants would not be required to pay the augmentation portion of the Replenishment Fee (currently $2,112/AF) on the amount of groundwater produced equal to the volume of recycled water the participants would receive. Participants would work cooperatively to develop a cost-effective use of the recycled water. To date, the IWVWD and Searles Valley Minerals, the two largest non-federal and non-agricultural groundwater producers in the Basin, have not joined the Recycled Water Program. On August 30, 2021, IWVGA Staff toured the Searles Valley Minerals water system facilities. Among other objectives and conclusions from the tour, it was concluded that Searles Valley Minerals does not have a substantial potential use for recycled water. An Option Agreement was adopted on November 19, 2020 between the City of Ridgecrest and the IWVGA. The IWVGA agreed to purchase available treated water from the City of Ridgecrest to mitigate against undesirable results caused by the over production of groundwater. The intent is to optimize reuse of recycled water.
In January 2021, the IWVGA Board of Directors authorized the development of a Recycled Water Use Alternative Analysis. The purpose of the analysis is to evaluate the potential uses of recycled water in the Basin and identify those uses that achieve the highest and most cost-effective benefits towards sustainable Basin management and reduction of imported water requirements. The analysis will provide a conceptual project design as a basis for initiating future design, permitting, and environmental compliance for the recycled water project. A recycled Water Working Group was formed consisting of
technical staff from the IWVGA (Stetson Engineers Inc.), the City of Ridgecrest (MKN), and the IWVWD (Krieger & Stewart). This analysis is still in development and will continue into WY 2022. In April 2021, Krieger & Stewart and Capitol Core, with assistance from Stetson Engineers Inc. and MKN, prepared a recycled water White Paper for use in the pursuit of funding.
See Corrective Action 3: Explain Water Budget Elements, Predict Recharge from Projects
Evapotranspiration (ET)
Current overall ET loss from the IWVGB is estimated at 4,850
See Corrective Action 3: Explain Water Budget Elements, Predict Recharge from Projects
Management Area – Watershed Basin (Inflows)
See Corrective Action 2 – Define the Connectivity of Three Hydrogeologic Zones, Fill Data Gaps
See Corrective Action 7 – Update Data Management System, Include Rationale for Updating Management Area Boundaries
Adjudication Resets Calculation and Distribution of IWVGA Fees
IWVGA Fee Calculation based on ?
The Judge will decide…
Recommended Corrective Action 1 – Provide Additional Information on Ongoing Communications with Stakeholders, Community Engagement Plan
Proposed Projects
1. City of Ridgecrest Recycled Water – Coso Geothermal
- Recycled Water to plant: Max production? 2,700 af per year
- Mutually beneficial cooperative agreement – Navy Liason
- IWVGA and Inyo County, Coso Geothermal, City of Ridgecrest, Indian Wells Valley Water District
- Imported Rose Valley via Coso interconnect: potential under Inyo County/Coso Geothermal terms af/yr?
2. Agriculture Trade/Exchange/Buyout (What % of 9,000 acre feet?)
3. Solar Development – Land Lease
Timelines
- Recharge Investigation and Modeling with Rose Valley/Coso Valley Sub-basins: 2022
- Acquisition/trade Agriculture: 2023
- Completion of Wastewater Treatment Facility: 2025
- Completion of Coso Recycle Project: 2025
Coso Geothermal Information
We can no longer ignore the evidence of known local water availability- Pat Farris, Publisher of The News Review, August 8, 2021
“If I wanted to become rich, I would seek council from someone who had become rich and gain from that person the pathway to riches. Likewise, if I wanted to find water I would seek council from someone who had discovered water. Now that we are seeking a water source for this valley, let’s take council from Dr. Carl Austin, Geologist, who spent more than 20 years in the exploration of water in this area.”
“As a consequence of his discovery, he developed the Coso Geothermal Power Plant at China Lake, the second largest plant in the United States and fifth largest in the world. Coso has pumped millions of gallons of water in the form of steam for the Navy for more that 25 years. This is rendering the Navy millions of dollars for that many years.”
163 23 CCR § 354.10(d). GSP Assessment Staff Report Indian Wells Valley (Basin No. 6-054) January 13, 2022 California Department of Water Resources, Sustainable Groundwater Management Program Page 44-45
STAFF RECOMMENDATION (7 Corrective Actions, 19 Items)
Department staff’s recommendation is to approve the Indian Wells Valley Groundwater Basin GSP with the recommended corrective actions listed below. The Plan conforms with the requirements of Sections 10727.2 and 10727.4 of SGMA and substantially complies, but does not fully satisfy, the requirements of the GSP Regulations. However, Department staff conclude that the current Plan is designed to achieve near-term progress towards groundwater sustainability, especially by reducing basin overdraft, whereas the deficiencies affect long-term conditions in the Basin. Department staff further conclude that the Authority should be able to address Plan deficiencies before they would affect the ability of the Basin to achieve sustainability. The Authority has identified several other areas for improvement of its Plan and Department staff concur that those items are important and should be addressed as soon as possible. Department staff have also identified additional recommended corrective actions that should be considered by the Authority for the first five-year assessment of the GSP.
Addressing these recommended corrective actions will be important to demonstrate that implementation of the Plan is likely to achieve the sustainability goal. The recommended corrective actions include:
Corrective Action 1 – Provide Additional Information on Ongoing Communications with Stakeholders, Community Engagement Plan
- Provide additional information on the required, ongoing communications elements required in the GSP Regulations,163 and describe how those required elements fit into the Authority’s Communication and Engagement Plan, including how it will continue to allow an open collaborative process with active diverse stakeholder engagement (such as those identified in the Communication and Engagement Plan’s Notification List, see Section 4.1.4) during Plan implementation.
Corrective Action 2 – Define the Connectivity of Three Hydrogeologic Zones, Fill Data Gaps
- Investigate the hydraulic connectivity of the vertical and lateral relationships between the three hydrogeologic zones within the shallow and deep principal aquifers to improve the understanding of potential migration of impaired water. Provide a timeline and discuss the steps that will be taken to fill the data gap identified in the Plan related to groundwater
monitoring. - During Plan implementation and in filling data gaps, the Authority should reassess the groundwater level and groundwater quality monitoring networks to include information about the amount of current and projected groundwater use and aquifer characteristics, including confined or unconfined aquifer conditions, or other physical characteristics that affect groundwater flow and how that flow could exacerbate groundwater quality challenges.
Corrective Action 3 – Explain Water Budget Elements, Predict Recharge on Projects
- Explain water budget elements and values as they are updated to include information obtained during GSP implementation, such as implementing groundwater allocations and finalizing imported water volumes. Tabular values, especially, should be explained and should not include mathematical errors (see Section 4.2.4).
- Describe how much of the predicted volumes of artificial recharge are attributed to each of the imported water and recycled water projects.
- Additionally, revise climate change projections based on data obtained from addressing data gaps, as needed.
Corrective Action 4 – Update and Include a Contingency Plan with Additional Projects and Managment Actions. The Plan should be Amended. Provide updates on negotiations and feasibility of imported water supplies. GA reported imported water was not to have been pursued in the WY20 Annual Report.
- Update the Plan to include projects and management actions sufficient to eliminate perpetual overdraft currently projected beyond the fifty-year planning and implementation horizon. Include contingency elements that would be triggered if water budget inflows are not increased over the rolling fifty-year planning and implementation horizon, particularly if imported water sources are not available.
- The contingency plan should include additional projects and management actions that may be implemented to achieve the sustainability goal for the Basin within and beyond the twenty-year timeframe of SGMA, in the event that the Authority is unable to implement projects and management actions described in the Plan or that those projects and management actions fail to produce the anticipated results.
- The Plan should be amended to include an updated and detailed timetable for the adoption and implementation of current projects and management actions, as well as an explanation of when and under what circumstances the Authority would implement alternative or additional projects and management actions, as needed.
- Provide updates related to the negotiated details and implementation of the imported water project options. Details are warranted regarding the feasibility of confidential supply sources (availability of water rights, infrastructure, and funding), particularly because imported water supplies were reported in the WY20 Annual Report not to have been pursued, and how they could be affected in times of drought and when sources for water importers are less than anticipated.
Corrective Action 5 – Identify Conditions Producing Undesirable Results, Minimum Thresholds
- Identify effects caused by groundwater conditions occurring through the Basin that would produce undesirable results based on significant and unreasonable impacts to applicable sustainability indicators.
- Minimum thresholds need to be identified to prevent conditions in the Basin from causing those undesirable results.
- Additionally, the Authority should provide relevant updates in Annual Reports and five-year updates to sustainable management criteria based on results from addressing data gaps and any observed impacts due to the implementation of proposed projects (e.g., the introduction of imported water supplies and infrastructure), such as water quality degradation and depletions of interconnected surface water.
Corrective Action 6 – Designate Representative Well Monitoring Locations
- During Plan implementation and before the first five-year assessment, establish sustainable management criteria at all wells the Authority intends to designate as representative monitoring locations, particularly for degraded water quality.
- In doing so, the Authority should collaborate and coordinate with the appropriate groundwater users, water quality regulatory agencies, and existing programs in the Basin to understand and develop a process for determining if groundwater management and extraction is resulting in degraded water quality in the Basin.
Corrective Action 7 – Update Data Management System, Include Rationale for Updating Management Area Boundaries
- Update the data management system to reflect correct and complete information and to comply with GSP Regulations.
- If the Authority intends to implement management areas in the Basin, include information describing the rationale for management area boundaries and their use consistent with GSP Regulations.
- Report information in a consistent manner in Annual Reports and on the Authority’s ‘GSP Dashboard’ website if the Authority intends to continue to provide Basin monitoring to the public on this platform.
- Information should be consistent between updates to the Plan, Annual Reports, and the data management system ‘GSP Dashboard’ page, including representative monitoring well locations and names, sustainable management criteria, and monitoring reporting data
Downloadable GSP Files and Annual Reports 2019-2021
January 2020: Indian Wells Valley Groundwater Sustainability Plan (GSP)
May 2020: Annual Report Water Year 2019
April 2021: Annual Report Water Year 2020
January 13, 2022: DWR Approval Letter, Staff Analysis and Corrective Actions
January 2022 (Final) Annual Report Water Year 2021
March 9, 2022 Meeting
This Report was prepared by Mike Sinnott, Resident
Publisher@Roadrunner395.com
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