HomeMy WebLinkAboutStaff Report 4.D 07/16/2018- -TIM, ED
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DATE: July 16, 2018
TO: Honorable Mayor and Members of the City Council through City Manager
FROM: Dan St. John, F.ASCE — Director, Public Works and Utilities
Leah Walker, P.E. — Environmental Services Manager
SUBJECT: Resolution Authorizing the City Manager to File an Application for Modification
of the California Department of Water Resources Bulletin 118 Defined Petaluma
Valley Groundwater Basin Boundary Based on Jurisdiction of the City of
Petaluma
RECOMMENDATION
It is recommended that the City Council adopt the Resolution Authorizing the City Manager to
File an Application for Modification of the California Department of Water Resources Bulletin
118 Defined Petaluma Valley Groundwater Basin Boundary Based on Jurisdiction of the City of
Petaluma.
BACKGROUND
The proposed action addresses changes being implemented by the California Department of
Water Resources (DWR) this year relating to the Sustainable Groundwater Management Act
(SGMA) to change the priority of a number of groundwater basins (GWBs) in the State,
potentially requiring additional groundwater sustainability agencies (GSAs) to be formed in
Sonoma County. In May, DWR released a draft 2018 SGMA Basin Prioritization to Bulletin 118
that categorizes the State GWBs and proposed elevation of the Wilson Grove Highland
Formation (Wilson Grove) GWB, which includes a portion of the City's northwest limits, from a
low to a medium priority. Prior to releasing the 2018 Basin Prioritization document, in January
2018 DWR opened a six-month window for GWBs to modify boundaries. Originally, the
deadline for basin boundary modifications was June 30, 2018 but was subsequently extended to
July 31, 2018.
Petaluma is already a participant in the Petaluma Valley GSA (PV GSA). If adopted as
anticipated, the elevation of the Wilson Grove GWB priority could trigger the requirement to
form another GSA that includes a portion of the City. The map in Exhibit A to the Resolution
shows these current GWB boundaries. Unless the subject PV GSA boundary modification is
approved, the City may be required to become a participant in a second GSA with its related
costs and staff resource demands, including Councilmember time spent serving on two different
GSA governing boards. The purpose of the subject action is to seek public input and Council
approval to petition DWR on behalf of the City to grant a "jurisdictional" boundary modification
of the PV GSA to take in a small portion of the Wilson Grove GWB that is currently within the
City limits. This would allow the City to focus its resources on groundwater management of the
entire City within a single GSA in the future.
In September 2014 Governor Brown signed historic SGMA legislation requiring California's
critical groundwater resources to be sustainably managed by local agencies by giving local
agencies authority to sustainably manage groundwater over the long-term. SGMA required the
formation by June 30, 2017 of new GSAs for each medium and high-priority groundwater basin
as designated in DWR's Bulletin 118. In Sonoma County, only three of the county's 14 GWBs,
Santa Rosa Plain, Sonoma Valley and Petaluma Valley, were originally designated as medium
priority and none as high or critical; and all three GSAs were formed by the June 30, 2017
deadline date. With the new Draft 2018 SGMA Basin Prioritizations, all three of the existing
Sonoma County GSA's GWBs were elevated from medium to high priority and Alexander
Valley, Healdsburg, and Wilson Grove GWBs were reprioritized from very low to medium
priority. While changing from medium to high priority carries no additional requirements for the
GSAs, moving from low or very low priority to medium or high requires compliance with
SGMA through either the formation of a GSA or submittal of an Alternative Plan within two
years of the new prioritizations becoming final.
The City Council held workshops on November 2, 2015 and November 14, 2016 to explore
options for GSA formation and management and on May 1, 2017 approved the City's joining in
the formation of a Joint Exercise of Powers Agreement (JPA) for the PV GSA joining with
Sonoma County, Sonoma County Water Agency (SCWA), Sonoma Resource Conservation
District (SRCD), and the North Bay Water District (NBWD) as managing agencies, with elected
members serving on the GSA Board. The JPA held its first meeting and public workshop in June
2017, filed its Notice of Intent to form the PV GSA with DWR by June 30, 2017, and held its
first official meeting as an authorized GSA in August 2017. The PV GSA Board considered the
merits of requesting a GSA boundary modification to address the proposed elevation of priority
of the Wilson Grove GWB at its recent June 21, 2018 meeting. The Board voted to support a
request for a jurisdictional basin boundary modification to incorporate the portion of the Wilson
Grove GWB within Petaluma City limits into the PV GWB.
DISCUSSION
Regulations promulgated by DWR in Section 340 and following of Title 23 of the California
Code of Regulations prescribe the processes by which local agencies may request modification
of GWB boundaries (Boundary Modification Regulations) as described in DWR Bulletin 118.
There are two parallel paths that can be taken to avoid the City having to serve in two GSAs. The
first path is to provide documentation to DWR that could result in Wilson Grove GWB dropping
back down to low priority and the second path is to modify the boundaries of the existing PV
GSA basin to include the western portion of the City that is currently mapped within the Wilson
Grove GWB. PV GSA staff is taking the lead in pursuing the first path and the City would need
to take the lead in the second path based on its jurisdiction within the City limits. Both
approaches are described below.
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Draft 2018 Basin Prioritization: DWR's basin prioritization involves classifying basins and sub -
basins based on a variety of factors identified in the law, including: (1) population; (2) projected
growth; (3) number of public water -supply wells; (4) total number of water wells; (5) amount of
irrigated acreage; (6) reliance on groundwater; (7) documented impacts; and (8) other relevant
information, including adverse impacts on local habitat and local stream -flows. Staff from PV
GSA and DWR have met to discuss data and submittal comments addressing these factors. At
this point, it is unclear as to whether the comments will result in the Wilson Grove GWB
dropping back to low priority.
Basin Boundary Modification: The 2018 draft prioritization of the Wilson Grove GWB triggered
the need for Petaluma to consider requesting a jurisdictional modification of the PV GSA
boundaries to include the western portion of the City. The City of Sebastopol is also affected by
the DWR action. SGMA authorized local agencies to ask DWR to revise the boundaries of
existing groundwater basins and directed DWR to adopt regulations governing modifications.
Under the Boundary Modification Regulations, there are two types of boundary modifications,
jurisdictional and scientific. A scientific modification considers geologic or hydrologic
conditions that define a groundwater basin. A jurisdictional modification involves the revision of
a basin boundary that is not scientific but promotes sustainable groundwater management, such
as by aligning boundaries with city, county or district boundaries. Unfortunately, the DWR did
not provide much time after releasing the draft 2018 Basin Prioritization for GSAs and other
affected jurisdictions to engage in a deliberative process and to prepare adequate documentation
to request boundary modifications. While DWR has extended the deadline for basin modification
from June 30th to July 31St, this extension provides a very small window of time for staff to
prepare documentation for a jurisdictional modification. There is insufficient time prior to the
July 31 deadline to submit a scientific modification request because such a request must include
a hydrogeological justification.
The jurisdictional boundary modification involves the least amount of technical justification
based on DWR guidelines, and begins with a public meeting and resolution from the affected
member agency, in this case the City. Other PV GSA members and potentially affected agencies
are being asked to offer letters of support. Based on the nearly completed USGS Groundwater
Study which has defined the technical study area for Petaluma Valley differently than DWR's
Bulletin 118, and includes those portions of the Wilson Grove GWB within the City, a minor
adjustment of the PV GSA boundary within the City Limits is not expected to provoke
significant technical opposition by DWR. As of this writing, there is no known opposition to the
proposal from affected agencies. Attachment 2 shows the minor aerial extent of the
recommended modification while Attachment 3 shows all the GWB's of Sonoma, albeit with
their old priorities as a point of reference. Integrating the entire Petaluma jurisdiction within the
existing PV GSA would avoid the potential for inconsistent or conflicting ground water
management approaches that may result from dividing a single municipality with local
regulatory authority over land and water use within its entire boundaries into separate
groundwater basins and GSAs. Staff is aware of no hydrologic or sustainable groundwater
management reason why the portion of Petaluma within the proposed Wilson Grove GWB
should be located in a separate GWB and GSA from the rest of the City.
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It is recommended that the Council adopt the proposed resolution and direct staff to work with
PV GSA staff to prepare the DWR application for the subject modification. If the Council adopts
the proposed resolution staff will notify DWR of the City's and PV GSA's intention to submit
the boundary modification request within 15 days of the Council's action in accordance with
Section 343.9 of the Boundary Modification Regulations. The City will solicit letters of support
for the boundary modification from the other agencies including PV GSA members. In
anticipation of the public meeting to discuss the subject, the City published a notice of the public
meeting in the Petalzinw Argus on July 12, 2018 to invite public comment on the matter.
FINANCIAL IMPACTS
No significant financial impacts are expected as a result of the proposed action other than staff
time necessary to compile the PV GSA Boundary Modification application. The cost saving to
the City by avoiding inclusion into a second GSA has not been estimated, but as a point of
reference, the City has committed to contribute $286,666 to the PV GSA during FY 17/18 and
FY 18/19, although that amount is expected to be reduced to less than $30,000 per year for the
three succeeding fiscal years.
ATTACHMENTS
1. Resolution
2. Exhibit A to Resolution: Map of PV GSA Proposed Jurisdictional Boundary
Modification
3. Sonoma County Groundwater Basins and Sub -Basins (prior to 2018 Draft SGMA Basin
Prioritization)
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RESOLUTION AUTHORIZING CITY MANAGER
TO FILE APPLICATION FOR MODIFICATION OF THE
CALIFORNIA DEPARTMENT OF WATER RESOURCES
BULLETIN 118 DEFINED PETALUMA VALLEY GROUNDWATER BASIN
BOUNDARY BASED ON JURISDICTION
OF THE CITY OF PETALUMA
WHEREAS, Governor Brown signed into law Senate Bills 1168 and 1319 and Assembly
Bill 1739, collectively comprising the Sustainable Groundwater Management Act (SGMA),
which took effect on January 1, 2015; and
WHEREAS, the SGMA requires all high and medium priority basins as designated by
the California Department of Water Resources (DWR) to undergo a process leading to
sustainable management through formation and operation of Groundwater Sustainability
Agencies (GSRs); and
WHEREAS, the City of Petaluma, on May 1, 2017 authorized the City to become party
to a Joint Exercise of Powers Agreement forming the Petaluma Valley Groundwater
Sustainability Agency (PV GSA) joining with Sonoma County, Sonoma County Water Agency,
Sonoma Resource Conservation District, and the North Bay Water District as managing
agencies, and the GSA is in the process of preparing a Groundwater Sustainability Plan (GSP)
for the Petaluma Valley Groundwater Basin; and
WHEREAS, Section 10722.2 of the California Water Code, part of SGMA, provides that
local agencies may request that the DWR revise the boundaries of a groundwater basin, and
requires that DWR adopt regulations specifying the criteria to be used to evaluate proposed
groundwater basin boundary revisions; and
WHEREAS, DWR has promulgated regulations in California Code of Regulations Title
23, Division 2., Chapter 1.5, Subchapter 1, entitled Groundwater Basin Boundaries, Section 340
and following (Boundary Modification Regulations) that specify the processes by which a local
agency may request a modification of groundwater basin boundaries as described in DWR
Bulletin 118; and
WHEREAS, in accordance with Section 343.2 of the Boundary Modification
Regulations, a request for a boundary modification may be initiated by a local agency whose
jurisdictional area lies within or borders an existing or proposed basin or sub basin for which
boundary modification is sought; and
WHEREAS, the City of Petaluma is a local agency whose jurisdictional area lies
primarily within the Petaluma Valley Basin with a portion of its jurisdictional area within the
Wilson Grove Formation Highlands Basin, and accordingly, the City of Petaluma is authorized
to request a boundary modification in accordance with SGMA and Section 343.2 of the
Boundary Modification Regulations; and
WHEREAS, the City of Petaluma is a California municipal corporation and charter
city, incorporated in 1858, with the power to regulate land and water use throughout the City's
corporate boundaries, including the entire area proposed for incorporation into the Petaluma
Valley Groundwater Basin, pursuant to the City's police powers under Article 11, Sections 5
and 7 of the California Constitution, the City Charter, the Petaluma Municipal Code, the
Petaluma General Plan 2025 and Implementing Zoning Ordinance, Ordinance No. 2300-N.C.S.,
and other applicable laws and regulations; and
WHEREAS, pursuant to its constitutional and statutory powers, the City of Petaluma
regulates land and water use throughout the entire City, including domestic and commercial
water supply relying on wholesale water purchases from the Sonoma County Water Agency
and production from the City's own wells, and connections to and operation of the City water
system, as well as operation of wells within the City; and
WHEREAS, the Petaluma Valley Groundwater Basin, basin number 2-01 in DWR
Bulletin No. 118, is currently designated by DWR as medium priority and is proposed to be re-
designated as high priority; and
WHEREAS, the Wilson Grove Formation Highlands Groundwater Basin, basin number
1-59 in DWR Bulletin No. 118, is currently designated by DWR as very low priority and is
proposed to be re -designated as medium priority; and
WHEREAS, modification of the Petaluma Valley Groundwater Basin boundary as
described in the map attached to and made a part of this resolution as Exhibit A would
incorporate the jurisdictional area of the City of Petaluma that is currently in the Wilson Grove
Formation Highlands Groundwater Basin into the Petaluma Valley Groundwater Basin; and
WHEREAS, modification of the Petaluma Valley Groundwater Basin boundary as
described in Exhibit A would promote sustainable groundwater management within the
Petaluma Valley Groundwater Basin and bordering Wilson Grove Formation Highlands
Groundwater Basin in accordance with the purposes of SGMA by avoiding the potential for
inconsistent or conflicting groundwater management approaches that may result from dividing
a single municipality, with local regulatory authority over land and water use within its entire
boundaries, into separate groundwater basins and GSAs; and
WHEREAS, the nearly -completed USGS Groundwater Study concerning the PV GWB
has defined the technical study area for the Petaluma Valley differently than DWR's Bulletin
118, and includes in the study area the entire City, including those portions of the Wilson Grove
GWB within the City; and
WHEREAS, City staff are aware of no hydrologic or sustainable groundwater
management reason why the portion of Petaluma within the proposed Wilson Grove GWB
should be located in a separate basin and GSA from the rest of the City; and
WHEREAS, Section 344.18 of the Boundary Modification Regulations requires the
requesting agency to satisfy requirements of the California Environmental Quality Act (CEQA),
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including, if necessary, information to enable the DWR to satisfy the requirements of a
responsible agency; and
WHEREAS, the proposed modification of the PV GWB boundary is not a Project as
defined by CEQA in accordance with Section 15378(b)(5) of the CEQA Guidelines because the
proposed boundary modification consists of organizational or administrative activities of
governments that will not result in direct or indirect physical changes in the environment;
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Petaluma
as follows:
1. The above recitals are hereby declared to be true and correct and to be findings of the
City Council.
2. The proposed modification of the Petaluma Valley Groundwater Basin boundary is
not a CEQA project in accordance with Section 15378(b)(5) of the CEQA Guidelines
because the proposed boundary modification consists of organizational or
administrative activities of governments that will not result in direct or indirect
physical changes in the environment.
3. The City Manager is hereby authorized and directed to file as the City's Request
Manager as defined in Section 341(w) of the Boundary Modification Regulations an
application for a modification of the California Department of Water Resources
Bulletin 118 defined Petaluma Valley Groundwater Basin boundary based on the
jurisdiction of the City of Petaluma in accordance with all applicable requirements of
the Boundary Modification Regulations and other applicable laws and regulations.
Attachment 3