29 June 2018

Nicole Bell Kern River Watershed Coalition Authority P.O. Box 151 Bakersfield, CA 93302

REVIEW OF THE KERN RIVER WATERSHED COALITION AUTHORITY’S GROUNDWATER TREND MONITORING WORK PLAN Thank you for the submittal of the Kern River Watershed Coalition Authority’s (Kern Coalition) Groundwater Trend Monitoring Work Plan (GTMW), required by Attachment B MRP Section IV.E of General Order Number R5-2013-0120. Central Valley Water Board staff has reviewed the GQTMP and determined that it is incomplete. If not adequately addressed in a timely manner, the deficiencies described in the attached review memorandum may impede the timely start of trend monitoring in your coalition area. The GTMW does not identify the wells that will compose the trend monitoring network, or include well details necessary to determine whether a selected well monitors an appropriate portion of the underlying aquifer system. Section IV.C.6 of the General Order requires a third-party group to: Conduct required water quality monitoring in conformance with quality assurance and provide timely and complete submittal of reports required by the General Order. The Coalition, as a member of the Central Valley Groundwater Monitoring Collaborative (CVGMC), has committed to begin sampling by fall 2018. To meet this commitment, you must provide the required well information in a timely manner. By 31 July 2018, provide an addendum to your Phase II GTMW that includes:

• Rationale supporting the number and location of trend monitoring wells selected for the monitoring network.

• A list of the wells that you have permission to sample and that compose your trend monitoring network

• A map showing the location of the trend monitoring wells

• All information required by General Order No. R5-2013-0120 for trend monitoring wells The Annual Monitoring Report’s due date (31 August) does not permit sufficient time for review and discussion of the previous year’s monitoring results before the start of the next year’s sampling. Therefore, at least 60 days before trend monitoring sampling begins for the 2018-2019 water year, but by no later than 1 May 2019, the Kern Coalition must meet with Central Valley Water Board staff to present the results of the previous year’s sampling and provide a discussion of the effectiveness of the sampling network and any proposed adaptive design

Kern River Watershed Coalition Authority - 2 - 27 June 2018 GTMW Review sampling, the following analytes will be sampled every five years: total dissolved solids (TDS), major anions (carbonate, bicarbonate, chloride, and sulfate) and major cations (boron, calcium, sodium, magnesium, and potassium). Summary of Staff Comments Central Valley Water Board staff reviewed the revised GTMW to determine compliance with the General Order. Based on staff review of the revised GTMW, additional information is needed to fully address the General Order’s Groundwater Quality Trend Monitoring requirements. Staff recommendations have been made on the Implementation, Work Plan Approach, Well Details, Proposed Sampling Schedule, Work Plan Implementation and Analysis, and Annual Groundwater Monitoring Results. Item numbers presented below are referenced from Table 1. Item 2b. Implementation Attachment B, Section IV.C.2 of the General Order requires the Trend Monitoring Work Plan to identify a groundwater monitoring network that will be implemented over both high and low vulnerability areas, and employ wells that consist of shallow wells or existing wells and monitoring networks. Staff Comments: The General Order requires that specific wells making up the Trend Monitoring network be identified within the GTMW. The initial GTMW states in Section 1.2.5: “Site specific wells were scheduled to be selected in Phase II of the GTMW. The Kern Coalition’s GTMW defines Phase II activities, including site specific well selection criteria and incorporates elements of the Central Valley Groundwater Monitoring Collaborative (CVGMC) technical work plan.” The Phase II GTMW does not present a well network, complete well details, or indication that permissions to sample proposed wells has been obtained. A schedule for obtaining these necessary elements was also not included. When selecting wells for the groundwater trend monitoring network the Kern Coalition should determine if those wells meet Attachment B, MRP Section IV.C.2 and draw water from the upper zone as defined in Section 3.3 and Figure 3-2 in the CVGMC Workplan. If selected wells do not represent the upper zone of the aquifer, then the Kern Coalition should select different wells that do fit these criteria for the GTMW network. The initial GTMW states in Section 4.2.1.4: “A number of the regions which lack data are located in areas without useable groundwater or wells, including, but not limited to, the Buena Vista Lake area. These locations will not be included, as only existing wells will be used.” This statement was removed from the GTMW, but staff’s comment regarding this matter was not addressed. Unless excluded by the Tulare Lake Basin Plan, all groundwater in the Tulare Lake Basin has the potential for MUN beneficial use and for other beneficial uses listed in the Basin Plan. Groundwater throughout the coalition area must be included when considering a trend monitoring network. The GTMW states in Section 4.2.2: “If less than 20% of a township is used for irrigated agriculture of [Kern Coalition] members, then no wells were selected for the township, regardless of weighted score.” These areas should be considered in the trend monitoring effort. Townships where less than twenty percent of the area is used for irrigated agriculture could be represented by wells in adjacent townships if crop type, soil, and hydraulic characteristics are similar, or by wells in nonadjacent areas if monitoring by commodity is considered. When selecting wells, the GTMW must identify the townships it proposes to exclude from monitoring and describe how the proposed or revised monitoring will represent these areas. The GTMW proposes the use of public supply well data for areas that were previously excluded in the initial

Kern River Watershed Coalition Authority - 3 - 27 June 2018 GTMW Review GTMW, including the Tehachapi and Lake Isabella areas. Wells selected in these areas will need to draw water from the upper zone as defined by the CVGMC Work Plan. The GTMW discusses well location considerations and scoring in Section 4.2.2. Vulnerability prioritization was considered in determining the number of wells per township, and included areas assigned by the Central Valley Water Board (Table 1). High vulnerability areas (HVAs) assigned by the Central Valley Water Board were assigned a midrange priority. Giving a midrange priority to these HVAs affects the coalition’s calculation on how many wells are used to monitor these areas. All HVAs should be assigned a high priority, unless sufficient rationale is provided to explain why HVAs are scored differently. Items 4, 4a, 4b, 4c. Work Plan Approach Attachment B, Section IV.E.1 of the General Order requires that the Trend Monitoring Work Plan provide details regarding the rationale for the number of proposed wells to be monitored and their locations. The rationale needs to consider: the variety of agricultural commodities produced within the third party’s boundaries, the conditions identified in the GAR related to the vulnerability prioritization within the coalition area, and the areas identified in the GAR that contribute significant recharge to urban and rural communities where groundwater serves as a significant source of supply. Staff Comment: An important and required aspect of the rationale has not been completely addressed; primarily, whether the number and location of the proposed wells constitute an adequate trend monitoring network that fulfills all Trend Monitoring objectives. This issue is not resolvable now due in part to the incomplete information provided for proposed wells and the uncertainties of landowner permissions to sample. The adequacy of the rationale cannot be understood without knowing the actual wells that will compose the network. This issue warrants further discussion prior to sampling for the 2018-2019 water year. Section 3.6 of the CVGMC Workplan proposes a “Dynamic Network: Adaptive Design and Refinement” where the monitoring well network is to be evaluated on an annual basis to determine if certain areas need additions, eliminations, or substitutions of wells. Given the uncertainties inherent in beginning an effort of this scope and the incompleteness of the well details (see Well Details below), the Kern Coalition should be required to annually evaluate and provide comment on the adequacy of the network to fulfill the trend monitoring objectives and propose any changes in the Annual Monitoring Report as noted in Attachment B, MRP Section IV.C.3 of the General Order. Annual evaluation information and changes to the trend monitoring network should also be discussed with Central Valley Water Board staff at least 60 days before trend monitoring sampling begins for the next water year. Any proposed changes should be discussed prior to the next years sampling. Item 5. Well Details Attachment B, Section IV.E.2 of the General Order states that the Trend Monitoring Work Plan must provide details for wells proposed for trend monitoring. Staff Comment: The General Order requires available well details must be provided for the wells selected for the trend monitoring network with the Kern Coalition’s GTMW. Missing well details include: GPS coordinates, physical address, California State Well Number, well depth, top and bottom of perforation depths, copy of well drillers log, depth to standing water, and well seal information. If some of these details and well logs are not available then this should be noted, and a description of resources consulted should be provided. If significant information is missing

Kern River Watershed Coalition Authority - 4 - 27 June 2018 GTMW Review from the well details, then a different nearby well with more complete information should be considered. Item 6. Proposed Sampling Schedule Attachment B, MRP Section IV.E.3 of the General Order states that Trend Monitoring wells will be sampled, at a minimum, annually at the same time of the year. Staff Comment: Sampling is proposed to begin no later than fall of 2018 in the CVGMC workplan and the Kern Coalition sampling should coincide with the CVGMC schedule. Annual sampling should occur at the same time of year for the duration of the trend monitoring effort. Annual well sampling must include all constituents required by Table 3 of Attachment B, MRP Section IV.E. If data from existing monitoring networks are used (e.g. municipal supply systems), analyses must include all constituents and parameters listed in Table 3 and the analytical results must be reported annually, or as required by Table 3. Additionally, samples collected during the early part of the 2018- 2019 water year (after 1 October 2018) should be reported and evaluated with the 2018 Annual Report due 31 August 2019. Item 7. Work Plan Implementation and Analysis Attachment B, Section IV.E.4 of the General Order states that the Trend Monitoring Work Plan must provide details regarding the proposed methods to be used to evaluate trends in the groundwater monitoring data over time. Staff Comment: Section 6.2.4 of the GTMW states that statistical analysis methods will be used to assess the existence of groundwater quality trends. Additional evaluation of data and analytical methods will be needed as the trend monitoring program evolves. The Kern Coalition should propose evaluation methods to support the CVGMC’s proposal for a “Dynamic Network: Adaptive Design and Refinement”. If inferential statistical methods are used, then the potential limitation of that method should also be discussed. Item 10. Annual Groundwater Monitoring Results Attachment B, Section V. B of the General Order requires; annually, by 31 August1, the third-party shall submit the prior year’s groundwater monitoring results as an Excel workbook containing an export of all data records uploaded and/or entered into the State Water Board GeoTracker database. If any data are missing from the report, the submittal must include a description of what data are missing and when they will be submitted to the Central Valley Water Board. If data are not loaded into the GeoTracker database, this shall also be noted with the submittal. Staff Comment: Section 6.2 of the CVGMC workplan states “It will be required of the member Coalitions to submit the EDFs to the CVGMC directly once they are loaded to GeoTracker; member Coalitions may elect to have their contracted laboratory submit to the CVGMC DMS on their behalf.” The Kern Coalition must deliver the data required in the annual report via Excel workbook containing an export of all data records uploaded and/or entered into the State Water Board GeoTracker database. Shape files, which will be needed for key figures/maps, can be included in a readable format and media type with the report submittals. Attachments: Figure 1: Crop Map and Proposed Monitoring Areas (Figure 14 in the GTMW)

1 As revised by the Executive Officer on 27 April 2017.

Kern River Watershed Coalition Authority - 5 - 27 June 2018 GTMW Review

Figure 1: Kern Coalition – Crop Map and Proposed Monitoring Areas (Figure 14 in the GTMW)

Kern River Watershed Coalition Authority - 6 - 27 June 2018 GTMW Review Table 1. Components of the Groundwater Quality Trend Monitoring Work Plan

Item No. Required Component Location in GTMW

Groundwater Quality Trend Monitoring As required by General Order Attachment B, Section IV.C

1 Objectives: Identification of objectives for Groundwater Quality Trend Monitoring being:

1a 1) to determine current water quality conditions of groundwater relevant to irrigated agriculture 1.2, 3

1b 2) to develop long-term groundwater quality information that can be used to evaluate the regional effects of irrigated agriculture and its practices.

1.2, 4

2 Implementation: Identification of developed groundwater monitoring network that will:

2a 1) be implemented over both high and low vulnerability areas 1.2, 4.2, Incomplete

2b 2) employ wells that consist of shallow wells or existing wells and monitoring networks

1.2, 4.2, Incomplete

3 Reporting: Results of trend monitoring including map of sampled wells, tabulation of analytical data, time concentration charts, and evaluation of data trends.

1.2, 6

Trend Monitoring Work Plan As required by General Order Attachment B, Section IV.E

4 Work Plan approach: Provide discussion of the rationale for the number of proposed wells to be monitored and their locations. Rational discussion needs to consider:

4, Incomplete

4a 1) the variety of agricultural commodities produced with the third-party boundaries

4.2, Figure 15, Table 4-1 & 4-2,

Incomplete

4b 2) the conditions discussed/ identified in the GAR related to the vulnerability prioritization within the third-party area

4.2, Table 4-1, Figures 16-19

Incomplete

4c 3) the areas identified in the GAR as contributing significant recharge to urban and rural communities where groundwater serves as a significant supply source.

4.2, Table 4-1, Figures 16-19,

Incomplete

5

Well details: Provide details for wells proposed for trend monitoring, including: GPS coordinates, physical address of the property where well is located, California State well number, well depth, top and bottom perforation depths, copy of water well drillers log, depth of standing (static) water level, and well seal information.

4.2, 5.2, Incomplete

6

Proposed sampling schedule: Identify when trend monitoring wells will be sampled. Sampling, at a minimum, should occur annually at the same time of the year for the constituents and indicator parameters lay out in Table 3 of Section IV.E. of the MRP Order R5-2013-0120.

5.3, Table 5-1, Incomplete

7 Work plan implementation and analysis: Discussion of proposed method(s) to be used to evaluate trends in the groundwater monitoring data over time.

6, Incomplete

Kern River Watershed Coalition Authority - 7 - 27 June 2018 GTMW Review

Reporting Requirements

8

Section 6735(a) of the California Business and Professions Code requires that all final civil engineering calculations and reports shall bear the signature and seal or stamp of the licensee and the date of signing and sealing or stamping.

Provided

9 Reporting provisions of the General Order require a certification statement for each person signing a report. Provided

10

Order Attachment B, Provision V.B requires that annually, by 1 May, the third-party shall submit the prior year’s groundwater monitoring results as an Excel workbook containing an export of all data records uploaded into the State Board Geotracker database.

Incomplete