Its year 3 of the drought - where is the focus on water?

An open request to the Board of Supervisors: In this 3rd year of a climate-driven drought, instead of hiring new staff to expedite cannabis permitting, the County should focus on completing the required baseline analyses of existing conditions. For water availability, the Baseline should quantify current drought-related water supplies versus existing residential, industrial, and wine industry demands.

This new industry is projected to grow an unspecified amount of water-intensive product, yet current analyses rely on out-of-date water supply data and little to no groundwater analyses in the areas where cannabis is grown. CEQA requires known and expected future projects be factored in: In addition to the proposed full Cannabis Program projections for cultivation and manufacturing/distribution water demand, other known water demands include State-mandated new housing, and county-wide projected commercial/industrial growth.

Sonoma County’s water analyses are woefully out of date and cannot be relied on: Temperature levels, desiccating wind events and rainfall patterns over the past 7-10 years are very different from historical 1980 data, or the water availability and land use assumptions in the General Plan Environmental Impact Report (EIR) completed over 15 years ago. Even the Agency’s Water Supply Strategies Action Plan, developed in 2010, with a 2018 update, does not reflect current climate-driven drought conditions. The 2023 update will be timely to data to the required baseline studies for the Cannabis Program EIR as well as water analyses required to update the General Plan.

Support groundwater monitoring database projected to be completed this summer: Most cannabis cultivation currently uses groundwater resources; however, the Neighborhood Coalition (NC) supports changing the focus to more lucrative, and environmentally sound indoor grows via greenhouse production in commercial/industrial zones. The NC supports Permit Sonoma’s current work to map and update our groundwater monitoring program, with funding through GSA Prop 68 grants.  The work required to make Use Permit-required groundwater monitoring data and other existing databases accessible via recording the data in the land use permitting database (Accela) will provide essential groundwater information guide land use decisions and required mitigations.

Water Workshop leaves many questions unanswered: As discussed at Sonoma Water Agency March 10, 2022 Workshop, Sonoma County faces a historic drought emergency. Many people believe that dryer than normal conditions or the conditions described by Supervisor Rabbitt - climate driven “weather whiplash,” such as the 2019 floods followed by the 2020-22 drought have become the new normal. FEMA also forecasts increased severity of drought, flood and fire damage.
There were many, many unanswered questions at the Town Hall, and their level of sophistication shows our citizenry requires better solutions than just cut back residential water use.

Proposed aquifer and stream recharge programs revealed that both the County and State agencies know Sonoma County has a water supply problem.  Forecasts, strategies and funding by the Sonoma Water Agency (Agency), benefit the storage and distribution of drinking water to 600,000 users in the County’s urban areas as well as Marin. Given the severe drought, the Agency is rehabilitating two wells expected to provide about 3.7 million gallons of water daily, as well as considering aquifer recharge in the Russian River watershed. Although there has been significant groundwater drawdown near the Wohler collectors, Agency reps did not answer the question about the potential impact of these wells on domestic and ag wells within their zone of influence.

As shown in the Agency’s Current Water Supply Level Chart, reservoir storage levels are about 60%. Equally concerning, at the Town Hall the County officials did not address known risks to supply, such as the loss of Eel River diversions given Potter Valley FERC license requirements. Measures being taken to address the increase in demand from State-mandated housing requirements were not explicitly defined. Unfortunately, the State rejected Permit Sonoma’s appeal to reduce or reallocate Sonoma County’s housing requirements given current zoning and water restrictions, as this appeal was supported by many community and environmental groups.

Strategy 3 of the Agency’s Water Supply Strategy document promised increased use of regional planning to provide water resiliency.  Recently, the recommended Groundwater Sustainability Area GSA reports for Santa Rosa Plain, Petaluma and Sonoma Valley were completed. Yet, Alexander Valley and the Healdsburg Area are still categorized as “low priority” despite being hit so hard by drought conditions that the Department of Water Resources limited water right diversions.  

Information on whether the County incorporated locally scaled Global-Climate Models (GCMs) into future climate projections for GSAs, as recommended by Strategy 3 would be useful. It’s generally understood that the GSAs used a 50-year precipitation data to populate modeled scenarios which tended toward moderate assumptions versus an analysis of worst-case conditions.  Another concern is the Petaluma GSA assumed no cannabis cultivation, even though permits have been issued.

Off-Stream Reservoirs and Catchment Basins: At both the March 9 and March 10 workshops, interagency teams presented a “voluntary drought initiative” for residents and commercial uses to supplement summer flows to enhance endangered species survival rates in impaired watersheds. Presenters recommended the creation of off-stream storage reservoirs to collect winter runoff for use and to provide stream connectivity in the summer. The speakers did not address whether analyses have been completed to assess the extent to which catchment basins impede groundwater recharge and potential dewatering of Class 3 or 4 small groundwater deposits relied on by downhill users.

One concern is that the very Federal and State agencies relied on by citizens to protect the ecosystem values (water holding capacity, wildlife, soil stabilization, and oxygen etc.) of our fragile watershed areas, appear to be turning a blind eye to the damage done by County approved cannabis permits, not to mention State-sanctioned logging.  

Neighbors impacted by cannabis operations in high-fire risk areas with very limited groundwater have written letter after letter requesting oversight and letters to Permit Sonoma and the Ag Commissioner from these agencies. And, when the Agency reps do submit testimony into the record, Permit Sonoma deems their input as “advisory only.”  If these watersheds and fishery resources are so important, then people in the Mill/Palmer Creek and Mark West Creek impaired watersheds should not have had to hire law firms to get basic water-related and environmental laws upheld.  

Conclusion: The County’s water availability studies need immediate update. It’s time to define the current baselines for surface and groundwater supply and future forecast demand in both normal and worst-case multiple drought years. Expediting the issuing of new cannabis permits prior to completing water availability analyses is irresponsible.

‍