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July Reflections

Gary Haldeman
BWD Ratepayer Representative Borrego Basin GSP Advisory Committee

Buenas tardes. It's been some time, but seems like a good time to remind us of our goals and to briefly review some of what's going on right now. For the sake of perspective, I'll copy our four main concerns, beliefs, objectives as stated in the last set of notes from May 29:



The July 9, 2019 BWD meeting agenda includes what is called the "Overview of Terms of a Potential Negotiated Solution Regarding Water Rights and Management of the Borrego Springs Subbasin." This appears to be an outline of a possible stipulated agreement among the basin pumpers, the details of which are protected by a confidentiality agreement.

Following are some of the salient points, to which I've added my comments:

There would be a 50% rampdown from current pumping levels over the first 10-year period beginning in 2020.

Comment: This "rampdown" is accelerated in terms of what the GSP proposed. In my way of thinking, a 50% reduction over a 10-year period of a 20-year plan simply means reducing an equal amount every year for 20 years. Sounds like the GSP plan was flawed and this "rampdown" is a way of correcting an error, not an acceleration of "frontloading" as it was called previously.
This also implies that this negotiated solution envisions a 20-year reduction period. So, our second objective will not be considered under this negotiated solution.

BWD will be allocated 2,222 + 359 in water credits = 2,581 AFY. The statement regarding the choice of the 2010-2015 base period is as follows: "The reason 2010-2015 is the BPA base period is because it immediately precedes SGMA."

Comment: We have argued that any such figure is too low; but have argued more consistently that BWD should be allocated 1,700 AFY untouched. Also, the "reason" for choosing this time frame is not based on any logic, as far as I can see. It's simply a choice (one that favors agriculture, as we've already argued and shown).

BWD has deemed that the Draft GSP "lacks governance, enforcement, equity, SDAC consideration and is expensive to implement." Thus BWD suggests that the GSP should become a "physical solution" as part of this negotiated solution, and not the guiding document.

Comment: So, after all the work, time, sweat and costs, not to speak of the input provided by the stakeholders, the GSP has now been deemed inadequate to the point that it will be merely a "physical solution," whatever that might be. Wow! What are we to think about this? Certainly raises questions and concerns. Did the folks crafting the document not suspect there were problems with it? How is it that for over two years the effort seemed to be conducted with integrity, good faith and a strong belief it was based on the best available science and would be a significant document? When, who and why was the document deemed inadequate?

A "committee of scientific experts will be established to advise the Water Master on GDEs and other matters."

Comment: There already exist numerous studies and commentary from "scientific experts" who have made it clear that the GDEs will unequivocally suffer from further and continued water table drawdown. Those involved in this negotiated solution are going to once again seek information from all of these scientists to accomplish what? It would appear that the result will be to continue kicking this GDE can down the 20-year road. Trustworthy and informed experts have already presented their views; these should be honored.

There's more stuff to look into, but this is certainly enough for you to think about. We're fortunate that Gary Edwards attended the AC meeting today and will provide us with some of his reflections on a meeting that should have taken place when we were all in Borrego Springs. We tried to get the dates changed, but had no success.

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