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Discretionary well permitting program

Sustainability Requirements, Stanislaus County, CA

Stanislaus County is one of the first jurisdictions in California to adopt a Groundwater Ordinance that requires permit applicants for new wells to demonstrate they will be extracting groundwater sustainably. Similar ordinances will soon need to be adopted by other jurisdictions across the State to comply with the Sustainable Groundwater Management Act (SGMA). These requirements will make issuing of well permits discretionary and subject to review under the California Environmental Quality Act (CEQA).

JJ&A assisted Stanislaus County to develop and implement a streamlined and defensible well permitting program that is fully compliant with the requirements of their new Groundwater Ordinance and CEQA, and is forward looking to the requirements of SGMA.

Development of Sustainability Evaluation Procedures and Permitting Program 
JJ&A developed a procedure based on applicable CEQA Initial Study thresholds, management objectives, trigger levels and response actions for each potential undesirable result that must be evaluated in order to demonstrate sustainability. These undesirable results include chronic local and regional drawdown of groundwater levels, depletion of groundwater storage, groundwater quality degradation, land subsidence, and surface water depletion. For each undesirable result, permit application requirements, action thresholds and standard permit conditions were specified. We also developed a program guide, permitting and CEQA evaluation flow chart, checklists for exemptions and application completeness, and a technical review form that assures a uniform and defensible approach is taken to each application. We are currently implementing the program for the County, including review of permit applications for compliance with the sustainability requirements of the Ordinance, and completion of CEQA studies.

Establishment of Special Groundwater Management Zones
One of the main challenges of the project was to develop criteria for sustainable groundwater extraction before a model is available to establish the sustainable yield of the County’s groundwater basins. Our solution focused on establishing special management zones where the County’s groundwater resources may be at risk of undesirable results, and requiring additional studies and monitoring in those areas.

For example, analytical groundwater modeling was conducted to evaluate potential stream flow depletion by groundwater pumping near the major groundwater-connected rivers in the County. The results were used to establish surface water protection zones outside of which the effect of groundwater extraction may be considered negligible, and inside of which additional studies and monitoring are required. Similar zones were established for groundwater quality, subsidence, and areas demonstrating evidence of chronic overdraft.

Program Environmental Impact Report (PEIR)
In order to streamline the County’s well permitting program and provide a more robust basis for groundwater management in the County, we assisted the County to obtain a Proposition 1 grant from the Department of Water Resources to prepare a PEIR that evaluates the potential environmental impacts associated with implementation of the County’s discretionary well permitting program. The PEIR was recently adopted and included construction of a county-wide surface and groundwater model to assess potential impacts related to drawdown, groundwater storage depletion, subsidence, surface water depletion, and impacts to groundwater-dependent ecosystems. Mitigation measures were adopted where needed and a streamlined program is currently being developed that allows local studies to “tier off of” the PEIR to demonstrate CEQA compliance.