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Part of the rationale for Napa's alternative plan is that the county has already conducted extensive work on groundwater sustainability before the SMGA came along, said Patrick Lowe, natural resources program manager with Napa County's Department of Public Works. He pointed to the 16 meetings held by the county's groundwater resources advisory committee between 2011 and 2014.
"We were already in a pretty good position," Lowe says.
Napa County presents a test for the SGMA and state regulator's ability to enforce it. "SGMA is monumental, path-breaking and game-changing," says Kiparsky. "But it's only as good as the backstop."
The backstop is the state Water Resources Control Board. Part of a political tradeoff for the new regulatory regime is allowing local authorities to come up with their own plan, he says. It will be up to the the Department of Water Resources to vet Napa County's plan. If the plan doesn't meet sustainability standards, the state board could reject it and require the county to form a GSA and GSP.
That's what Chris Malan would like to see. Malan, executive director of the Institute for Conservation Advocacy, Research and Education in Napa County, an environmental nonprofit group that focuses on water issues, calls the county's pursuit of an alternative plan an "end run" around the SGMA.
In particular, she says the Napa Valley Sub-Basin shows signs of undesirable results, like subsidence and poor water quality, and says plans for monitoring are inadequate and based on poor well sampling. She says the alternative plan sidesteps the conversion of Napa Valley hillside woodlands into vineyards, a practice she says reduces critical groundwater recharge.
"This is the hallmark water issue of our time," says Malan.
Geologist Jane Nielsen doesn't think Napa's plan will pass muster with the state. Nielsen is a California-licensed geologist who worked for the U.S. Geological Survey. She co-founded the Sebastopol Water Information Group and the Sonoma County Water Coalition. She represents the water coalition on the Santa Rosa Plain Groundwater Management Panel.
After reading Napa County's sub-basin analysis, she said the groundwater monitoring program is "aspirational" and lacks sufficient enforcement to bring its goals and into reality.
She adds that the report provides a "very barebones" sketch of the kind of data that SGMA requires and there is no integration of the data sources.
"I would not be too optimistic that this program will be accepted as equivalent to a GSP," she says
Nell Green Nylen, a senior research fellow at Berkeley's Wheeler Water Institute, says it's important to note that the SGMA is still a work in progress.
"I would think the state will take a hard look at [Napa County], but I don't know how it will play out," she says. "The devil is in the details."