Our experience in trying to influence Napa County’s Groundwater Sustainability Plan (GSP) to be more preventive, inclusive, and sustainable were described in an article in the Redwood Chapter newsletter, here.

Why do we care and wish to participate when the official groundwater planning process is populated by many interested and expert individuals selected by the county? It’s because we see a difference between the values of the Sierra Club and the process of creating this groundwater sustainability plan. Photo credit: Fernando Vergara

The Sierra Club Values

The Sierra Club was founded with the mission to preserve natural environments and to respect natural ecosystems for the benefit of all communities and posterity. The Sierra Club has a developed water policy (https://www.sierraclub.org/policy/water-policy) that expresses the values of conservation and sustainability with respect to water and all systems dependent on water flows.

Conservation

Conservation and preservation of natural systems is more than aesthetic appreciation of wild lands. Evolution has developed very complex interdependent systems where living and physical environments are in stable balance. Disruption of one part of the system can quickly result in chaos and destruction of dependent systems in a failure cascade.

We respect the complexity and appreciate that our best scientific knowledge of the interdependencies may be inadequate to predict the impact of human caused interventions.

We therefore strongly support a very conservative view of development in natural environments. We support conservation of forests and woodlands, and of natural water flows, regardless of the legal jurisdictions they flow through. After all, Mother Nature only knows boundaries created by physical forces, not those created by committees.

Sustainability

Use and development of natural systems must be with the rule of sustainability. Taking of a resource must not exceed the system’s ability to heal and reestablish stability. Restraint, patience, and prevention are key to sustainability to assure that failure cascades are not initiated. Depleting or developing natural systems to the point where failures begin is not a sustainable approach to resource management. The reversal or mitigation is rarely sufficient to restore balance, and can lead to another cascade of consequences.

Sustainability requires careful application of predictive indicators that enable action before system failures start. Indicators should detect early trends or patterns suggesting departure from stable patterns.

In the interest of all communities, human and natural, we require that all systems be sustainable and not reactive, particularly those that carry the label of “sustainable.”

We see the uncertain future

Managing for sustainability is challenging, but additionally, climate change is throwing uncertainty at us. Is sustainable in stable times is also sustainable with climate change factored in? With a general trend toward hotter and drier climate compounded by higher variability, sustainability management must anticipate experiences that are unprecedented and not just replications of prior difficult years. With the past becoming less of a predictor of the future, we have to plan on not the probable, but the possible. We need to plan for the extreme events and patterns. Sustainability management needs to incorporate the latest of unfolding science of climate change. Climate models from a decade ago appear naïve as climate change has quickly surpassed the predicted scenarios. The authors of the GSP know this, but didn’t address it.

We support the principles driving SGMA

The Sustainable Groundwater Management Act attempts to codify the requirements of sustainable management, but leaves the interpretation and implementation to the various Groundwater Sustainability Agencies (GSAs) in the expectation that they will embrace both the letter and principles of sustainability, as well as bring research and understanding of local issues, drivers, and interdependencies in resource management.

When adherence to the letter of the law is not enough, we expect our leaders to rise to the opportunity.

The Napa GSP is very responsive to the letter of the law. The process also avoided the larger issues that impact actual sustainability. It is less responsive to the laws of nature. We must be mindful that when laws of humans conflict with laws of nature, Mother Nature always wins.

Our critical issues that need to be addressed

Our review of the GSP has focused on a few issues we consider critical drivers of the ability to manage for actual sustainability. We have commented on drafts and attempted to address the GSPAC directly, but have received reactions, but no engagement or substantive responses. We will reiterate the few that in our view are absolutely necessary to have management of sustainable groundwater resource:

• Consider the whole system

The focus on sub-basin groundwater at the expense of the valley’s whole water system is to create human boundaries where there are none in nature. Data should be gathered from all wells in the valley and the watershed to understand groundwater levels, amounts extracted, and the impact those extractions have on surface water.

The plan should better address groundwater dependent ecosystems, and gather data and manage water not on annual bases, but on the time periods that are critical to flora and fauna that need water flows at particular times of the year and not on an annual basis. Questions, data, and discussions of the whole valley and the impact of each domain on others should be allowed, encouraged, and taken into consideration. 

• Use preventive indicators to manage

We are concerned that the measurement of “undesirable effects” (with slow triggers for action) are reactive. Each of the indicators is a sign of early failure of sustainability management, akin to preventing house fires by waiting until you see flames. There are methods of establishing predictive indicators that employ simple statistical methods. Given the slowness of response of human systems, we need all the lead time we can get.

• Be collaborative and inclusive

The system by which county elected officials and their appointees designate the participants in the planning process is not collaborative. Refusal to engage in dialogue with interested and well-informed groups is lamentable. There are many examples of true collaboration in other parts of California; we hope that Napa will take lessons from those efforts and implement a more effective and sustainable process.