The groundwater sustainability plans that were submitted to the Department of Water Resources in January of 2020 were the first of the groundwater sustainability plans to be completed. Public review of these plans has revealed some important lessons to be learned to be considered for those preparing the plans that will be due in January of 2022. At the 3rd Annual Groundwater Sustainability Agency Summit hosted by the Groundwater Resources Association online in June, a panel of NGOs that had completed a review of the plans summarized their findings from the perspective of underrepresented beneficial users and with respect to stakeholder engagement, providing insights and recommendations for the upcoming plans.
Approach to the groundwater sustainability plan review
The Groundwater Leadership Forum is a group of environmental justice NGOs, natural resource NGOs, and academic institutions that was convened by the Water Foundation. With the first groundwater sustainability plans being submitted to the Department of Water Resources earlier this year, a subset of the group was interested in evaluating how vulnerable beneficial users were treated in the development of the groundwater sustainability plans.
The group chose 30 of the 50 groundwater sustainability plans to be submitted to the Department, selecting at least one GSP per critically overdrafted basin. They considered where there was existing coverage from their partner organizations, and whether there was potentially the presence of small drinking water systems, groundwater dependent ecosystems, and disadvantaged communities when selecting the plans to review.
The group looked at how climate change was incorporated into the plan, how disadvantaged communities were engaged and considered, how the plan dealt with groundwater dependent ecosystems and interconnected surface waters, if there were considerations for drinking water, and how stakeholders were engaged.
They reviewed 30 draft GSPs and provided those comments directly to groundwater sustainability agencies as technical feedback to help support them in their plan development process and to hopefully improve the plans before their final submission to DWR. After the final plans were submitted, the group then revisited those plans to review how the groundwater sustainability agencies responded to their comments.
The group did an overall of assessment of whether they thought the plan was deficient, incomplete, or insufficient, but Ms. Arthur acknowledged that the plans are living documents that, through adaptive management, will be changed and updated over time as data gaps are filled.
“Our comments focused on the key requirements in statute and in the regulations around drinking water, groundwater dependent ecosystems, climate change, and stakeholder engagement,” she said. “We wanted to see these topics included from the beginning of SGMA so that as the plans are updated and as basins are adaptively managed, these vulnerable communities are a part of the plans and the topics are built upon going forward.”
The group selected five areas or indicators of the groundwater sustainability plan that were most relative to their areas of concern or interests: the identification and consideration of beneficial users, the water budget, notice and communications, monitoring network, and projects and management actions. There were specific questions that were then evaluated for those indicators.
In all of the comment letters that they submitted on the draft versions of the plan, they provided a detailed review form that highlighted the sections of the regulation relevant to the question they were asking and a series of yes/no questions where they evaluated the presence or absence of information in the groundwater sustainability plan.
Then they provided a summary at the end to capture their overall findings in that section of the plan. For the review of the final plans, there was an additional column that basically looked at whether the groundwater sustainability agencies made changes between the draft plan and the final submission.
“I want to point out that we were limited in our capacity and ability to look at everything so we really were looking at the presence or absence of information,” Ms. Arthur said. “We weren’t ground-truthing or checking data quality and looking at that local information.”
Ms. Arthur than gave the findings of their review of the 30 groundwater sustainability plans.
Identification and consideration of beneficial uses
The slide shows the results for identification and consideration of beneficial users indicators. The graph on the right corresponds to the questions to the left. She noted that where the numbers don’t add up to 30, it’s because sometimes the questions weren’t applicable to all of the plans.
“We looked particularly at the identification of disadvantaged communities,” she said. “If folks didn’t do that or didn’t show an effort to do that, we considered that to be an insufficient plan. It’s a fundamental step that the GSAs needed to take to develop their GSP.”
“We looked at the direct and cumulative or indirect impacts of undesirable results, measurable objectives, and minimum thresholds on disadvantaged communities,” she continued. “We also looked at whether folks identified groundwater dependent ecosystems completely and consistent with guidance, and for the most part, 25 out of 30, folks did not do that completely and consistent with guidance.”
The group next looked at the water budget, focusing on how the groundwater sustainability plans included climate change and whether native vegetation and managed wetlands were included in the water budget as distinct water sectors consistent with regulations.
“You can see that most folks did incorporate climate change and follow DWR guidance there,” Ms. Arthur said. “We have about half of the plans that did not include the wet and dry scenario in climate change, and about half of the plans did not include native vegetation or managed wetlands as a distinct water sector. We recognized that some of the water budgets may have this information in the background of their analysis, and what we were looking for was the clear representation of that so that stakeholders could evaluate how those interests were being dealt with in the plans.”
Notice and communication
With respect to notice and communications, they were evaluating stakeholder engagement.
“Obviously stakeholder engagement is much more involved than this, but this was the most basic way to assess in a plan whether stakeholder engagement was conducted and really to look for areas where folks weren’t doing stakeholder engagement at all,” said Ms. Arthur. “We did find some plans that weren’t documenting how disadvantaged communities or environmental stakeholders were given opportunities to engage, and we also looked at the presence of a stakeholder community engagement plan and including outreach and implementation going forward in during the implementation process.”
For the monitoring network, specifically, they were looking at how the network monitors vulnerable communities, disadvantaged communities and groundwater dependent ecosystems.
“We did want to see the monitoring wells overlayed with disadvantaged communities and groundwater dependent ecosystems,” said Ms. Arthur. “In some cases, that information may have been represented separately, but without access to the actual shape files or direct information, what we wanted to see was those pieces of information overlaid with one another so that interested stakeholders can understand how the monitoring network deals with or will account for and be able to monitor impacts to disadvantaged communities and groundwater dependent ecosystems. Most folks did include a plan to identify and fill data gaps in the monitoring network.”
Project and management actions
The last indicator is project and management actions. “We were really asking whether overdraft was addressed at all in the first five years of the implementation period, so in this case, 2020-2025,” Ms. Arthur said. “Our assessment of the projects and management actions was limited in scope and limited in depth. What we did is we took all the projects in the GSPs at face value. We didn’t verify any of the claims about water supply benefits or demand reduction; we just took what was quantified.”
They only counted the proposed projects that had a funding source either identified or secured. “So for example, if the plan said that funds from a 218 process were going to be used but that process hadn’t started yet, we would still count the water supply benefits in doing this assessment here.”
What they found was that the overall median amount of overdraft addressed was 10% in the first five years; twelve plans didn’t address any overdraft or didn’t have any plans to address overdraft in the first five years; seven plans had over 50% that they planned to address in the first five years.
“This is relevant to the vulnerable communities that we’re working with, because the continuing decline of water levels can have impacts to drinking water wells and to groundwater dependent ecosystems,” she said.
They also considered whether the project and management actions identified potential impacts to water quality. “We found that about 2/3rds here did not look at or did not have plans to look at potential water quality impacts of projects and management actions,” Ms. Arthur said. “It was an area of concern for us to make sure that future projects going forward are not going to have potentially unintended consequences for these disadvantaged communities and groundwater dependent ecosystems.”
Looking forward to 2022: Nature components
Sandi Matsumoto, Associate Director of the Water Program at The Nature Conservancy, next discussed considerations for groundwater dependent ecosystems and other environmental components of the plans. She reminded folks that there are requirements in the Act that require consideration of groundwater dependent ecosystems that are embedded throughout the requirements of the regulations.
“There are certain requirements specifically that call out groundwater dependent ecosystems, but there are also a lot of requirements around beneficial users so as you look through the regulations, it’s helpful to key in on those requirements,” she said. “Basically the takeaway is that once you identify those beneficial users, particularly the environmental users, there are requirements to consider them throughout the plan.”
Groundwater dependent ecosystems (or GDEs) are plants and animals that get a portion of their water supply from groundwater; this includes rivers, springs, wetlands, and a variety of landscapes across the state from the north and the Shasta River down south and out to the desert, and are common across the landscape, she explained.
Ms. Matsumoto said that it’s important to recognize that groundwater dependency can vary during the year and depending on the season, a system may depend on groundwater differently. For example, a stream that’s flowing in September after the snowpack has melted is probably flowing from groundwater if there are not reservoir releases. Additionally, in a river or stream, there may be certain reaches that are more groundwater dependent than others, which is a reflection of the high variability of California’s Mediterranean climate.
“It’s thinking about it over seasons, over water year types, drought versus wet years and then thinking about it spatially as a river system may depend on groundwater differently in different reaches,” she said.
Ms. Matsumoto said that the reason it’s important is that since the 1900s, 92% of the groundwater dependent ecosystems in the Central Valley have been lost due to groundwater pumping and land conversion.
“The parts that we’re talking about in these plans for the most part are the little bits that remain and that is why we’re so concerned about what’s happening with them,” she said. “We’re holding on to the last bits that are left and so every additional loss of these systems is pretty significant because we’ve lost so much already.”
In order to help groundwater sustainability agencies meet the requirements of SGMA, the Nature Conservancy has developed the Groundwater Resource Hub. The website has information on the basics of what groundwater dependent ecosystems are, the requirements, and then tools to help agencies work through the various steps of meeting those requirements.
Identification of beneficial users and uses
There is a document that provides guidance for identifying what the environmental beneficial users are and considering them through plan development, including the projects and management actions and the monitoring plan.
“If you don’t identify the environmental beneficial users at the beginning, then they are left out of the plan all the way through,” said Ms. Matsumoto. “That’s probably the biggest challenge that we saw both for environmental beneficial users as well as drinking water beneficial users is that missing that early step really has consequences for the entire plan, and so making sure that you spend enough time on Step 1 is really important.”
“Where there are questions, just include them as potential,” she advised. “If you don’t have enough information to say that they are affirmatively groundwater dependent, keeping them in as potentially groundwater dependent until you have the data to prove otherwise is really important because otherwise you’re missing all the other steps in the process.”
Natural Communities Dataset Viewer
The Nature Conservancy worked with the Department of Water Resources and the Department of Fish and Wildlife to create an online database, the Natural Communities Dataset Viewer, that is freely available and a starting point for groundwater sustainability agencies to identify where groundwater dependent ecosystems might be located.
In the mapping application, users can find places on the map where groundwater dependent ecosystems might exist and then drill down into the data to find out what the mapping is based on, who mapped it and when, and other information about the data.
“You have the starting point that things that are potentially groundwater dependent,” said Ms. Matsumoto. “We provided that information, knowing that the best information is at the local level and you need that local layer of information understanding of the groundwater system to verify groundwater dependency.”
She acknowledged it is one of the trickier pieces, and in the some of the plans they reviewed, folks were using approaches that were not technically correct.
“If you have a groundwater dependent ecosystem that’s mapped, and you’re trying to understand if it is groundwater dependent and if it is something that we need to be considering in our plan, using depth to groundwater is a really easy way to help filter groundwater dependency,” she said. “However, in doing this, it’s important to understand that the system’s groundwater dependency can vary temporally and spatially. So as you’re looking at depth to groundwater measurements, looking over both wet and dry years and understanding the variability seasonally over those periods is the way to apply this depth to groundwater information.”
“So rather than picking one moment in time at one place, making sure that you have the data that really reflects the inherent dynamics of the system is the right way to do this,” said Ms. Matsumoto. “You’re already looking at this information for most of the other components of the plan so it’s just applying that lens to these GDEs when you’re looking at groundwater dependency.”
Surface water inputs
It can be confusing when surface water is involved, because the question of whether it is groundwater dependent or not becomes harder to understand.
“There can be cases where there are surface water inputs and that the GDE is in fact groundwater dependent, because while it may rely on surface water some of the time, it also may depend on groundwater other times,” said Ms. Matsumoto. “The language in the regulations is if it is dependent at any point in time, you want to be looking at it. So if there’s a surface water input, you also want to look at, is it a GDE? Is it a plant or animal that is generally dependent on groundwater? We have that information and list of species available on our website.”
So GSAs need to be sure they are making the connections and understanding the complexities of the groundwater and surface water interaction and the dependency of the species both, recognizing that it is possible for it to be dependent on surface water and groundwater at different times and different places.
“I think the lesson learned from the 2020 plans is if there is surface water, it doesn’t necessarily mean that it’s not groundwater dependent,” she said.
Interconnected surface water
Ms. Matsumoto said that there was a good degree of confusion around when surface water is interconnected and when it isn’t. California inherently has a lot of streams that are intermittent which is their natural state, so they may have flows at some times during the year and not during others.
“In some cases, we saw that they were excluded just on the basis of being intermittent streams, but in fact, what you want to focus on is whether there is a connection at any point, both spatially and temporally,” she said. “If seasonally, it’s only dry in the summer, it may still be groundwater dependent in the other seasons. And so understanding that by reach is an important way to verify whether these streams and surface water bodies are interconnected.”
“The environmental user checklist boils down all of the requirements,” she said. “It’s a couple pages and has all the information on where there are requirements to be addressing environmental beneficial users, and you can use it as a way to make sure it is incorporated into your plan.”
Looking forward to 2022: Drinking water concerns
Jennifer Clary, Water Program Manager at Clean Water Action next discussed concerns around drinking water and disadvantaged communities. In the review, she was trying to understand how the groundwater sustainability plans addressed stakeholder engagement and impacts on drinking water users, and in particular, how the plans considered human right to water, which was adopted as a state policy by the legislature in 2012.
She reminded that groundwater sustainability agencies are required to identify disadvantaged communities and domestic well users. “You’re required to engage them and then also consider their interests in developing the plan,” she said. “These are building blocks. If you don’t identify beneficial users, you can’t engage them. If you don’t engage them, you don’t know how to consider their interests in developing sustainable management criteria, which is the foundational piece of what we thought was sort of a pass/fail component of our sustainability plans in identifying disadvantaged communities.”
The Department of Water Resources posted a database of disadvantaged communities that was based on census data. She acknowledged that almost all the plans did this so they were certainly adequately and sufficient. So in moving forward, how can this be improved? One difficulty with census data which a few of the plans pointed out is that the whole basin is a disadvantaged community, so what should the GSA be doing?
“It’s a detailed scientific analysis of disadvantaged unincorporated communities,” Ms. Clary said. “It was before well drilling logs were public, so they went to the assessor’s office and developed polygons to look at parcel density. Where there was a parcel density of 250 per acre, they would do a site investigation to determine if it was actually a community. Given the fact that counties are part of GSA process and the fact that we’re looking at local information, moving forward, we need to think about how we take the basic building block of census data and improve it with local information.”
With respect to stakeholder engagement, Ms. Clary said the plans they reviewed were generally adequate. However, one thing that was not done well in the majority of the plans was identifying Native American Tribes; two-thirds of the plans stated there were no tribes in their basins and only two of those plans actually indicated the data source they relied on.
“Most of these plans that said they had no tribes didn’t make much of an effort (or any effort that we could determine) to actually identify where there were tribes,” she said. “This is really important because you need to really engage tribes in the development of the GSA, not even the GSP, because they are water users and they have authority over water, so this is something that I think is really concerning and has to be addressed moving forward.”
Moving forward, Ms. Clary recommended folks think about how the CV-SALTS program is engaging communities in their early action plans which are required to provide interim water supplies for affected communities. She said the State Water Board has developed guidance for this which provides good information and some basic key elements for successful community engagement
“To the extent that you can piggyback on what’s being done in that process I think is going to make everyone’s job a little easier so I recommend that you look at it,” she said. “Moving forward in implementation, you have the opportunity to really obtain a better understanding of the communities that you’re identified and engaged with moving forward. There’s a lot of expertise being developed, and I look forward to that continuing because I think it can only be beneficial for the communities.”
Prop 1 Disadvantaged Community Involvement Program
“There’s been a lot of work going on with that and although the timelines didn’t quite sync for the 2020 GSPs, taking that investment that’s already been made and integrating it into the plans and moving forward with the plans seems like a no-brainer,” she said.
Domestic and shallow wells
The biggest and most difficult piece is considering beneficial uses and users, said Ms. Clary. “I think this is where a lot of the plans could have done better. The difficulty is that where you have shallow wells, domestic wells, or small community water systems; those communities are disproportionately low-income communities of color and they are disproportionally impacted by falling water levels. So considering their interests could be making some difficult decisions – you either let their wells go dry or you let farms go dry. I understand it’s an extremely difficult decision, but not having that discussion isn’t going to make it easier over time.”
The Department’s well database has locations and well depths, but she noted that only about 20% of the plans included the depths of domestic wells. “Not including the depths of the shallowest wells is not really a good idea because you don’t want another East Porterville to happen in your basin on your watch,” said Ms. Clary. “Even if you’re working really hard at achieving your measurable objectives, it’s not going to look good if hundreds of people lose their wells and you don’t understand that’s going to happen. If you’re not doing the due diligence, you’re not going to know.”
The Water Foundation just published a technical analysis of domestic wells in 26 GSAs and 10 basins in the San Joaquin Valley, and they found that even at measurable objectives, between 17 and 23% of wells are going to be dewatered.
“It’s not going to be like 4% a year over the next 20 years,” said Ms. Clary. “When we have a serious drought, we’re going to have a serious problem and understanding where and how that could happen and what you can do to avert it or mitigate it is hugely important. And I know that a lot of environmental justice organizations have proposed that GSPs have a well mitigation program so they can address wells as they go dry. I strongly encourage GSPs get moving and develop those programs. I understand its money, but these communities are disproportionally impacted and they are the ones that are going to feel the effect of your decisions, whether good or bad, so I urge you to pay a lot of attention to it.”
Ms. Clary acknowledged that the regulations weren’t very clear on water quality and there are other regulatory programs that address water quality.
“Water quality is a huge issue for communities, particularly communities dependent on shallow groundwater because shallow groundwater is more likely to be impacted than deep groundwater,” she said. “So if you’re below the Corcoran Clay, you can have problems with arsenic, but if you’re above the Corcoran Clay or you have shallow groundwater, you’re more susceptible to surface water contaminants like nitrate and 1,2,3 TCP.”
“They are also subject to impacts or benefits based on management actions,” she continued. “Groundwater recharge, which was identified by almost every GSP as an option, changes groundwater chemistry. It can do two things. Some studies have been done on targeting groundwater recharge to mitigate nitrate contamination or targeting groundwater recharge to maintain well depths in areas with a lot of domestic wells. But groundwater recharge can also mobilize contaminants like uranium, and we’ve seen that happening significantly in the Central Valley, so understanding that before you get invested in a project seems like common sense. It’s something that can really help communities as well.”
Ms. Clary concluded by recommending the Stanford report, A Guide to Water Quality Requirements Under SGMA.
Question: How does one differentiate a wetland that is dependent on trapped surface water from one where there may be higher groundwater levels that’s probably a GDE?
“I think the Central Valley is tricky,” said Sandi Matsumoto. “One of the things that we’re finding is even in areas where there are really low groundwater levels, there are perched aquifers, and the lack of mapping and understanding of where those systems are and how those systems interact with the main part of the aquifer is one of the challenges. In some cases, folks are differentiating between the two, even though there is actually a connection between the shallow aquifer and the larger managed part of the aquifer.”
“The first level question is, is there a connection there?” she continued. “In many cases, there is, so it’s possible that the shallow aquifer is still impacted, albeit at a slower rate than the main part of the aquifer, so in many cases, the distinction between the two may not necessarily be helpful, to the degree that there is or a lack of understanding of what’s going on in the shallow aquifer. We’re finding that is one of the areas where there is a bigger data gap, and so having monitoring of the shallow aquifer at shallow depths is something that over the next five years, we hope to see some of those data gaps filled because understanding those dynamics is part of getting at, is that a useful distinction? Are they actually separate or are they connected?”
Question: In the instances where you’ve identified the missing elements or elements of a GSP, how often does it appear that data gaps are driving that missing element? Since we’re looking forward to 2020 GSPs, how might this be addressed differently moving forward in a future GSP?
“Data gaps are a huge piece of the issues we were looking at,” said Jennifer Clary. “But we’re not always seeing data gaps identified. Like having well depths, like having a better understanding of what wells were go dry at what point. That’s apparently not seen as a data gap in all plans. That’s the missing piece moving forward is before you consider what you are going to do about something, you have to really have a better understanding. We know that the well database needs to be improved, that we need to do local well surveys, and that we need to know more about abandoned wells, so those are all things that will improve our knowledge.”
“In our review of the 2020 plan, generally we were looking at whether folks were at least identifying a data gap, calling that out, and then describing a plan to fulfill that, or an intent to fill that,” added Samantha Arthur. “A lot of what I showed in the results there were folks just being silent on those topics, versus saying these are potential GDEs and we’re going to figure that out over time. So I think that was an overall takeaway for us was where there’s data gaps, it would helpful to represent those clearly.”
Question: To what extent should uncertainty in the data that’s available for planning be addressed by erring on the side of caution? As in the precautionary principle?
“I like precaution,” said Sandi Matsumoto. “I think if an ecosystem is possibly groundwater dependent, treating it as such throughout the plan will avoid causing unintentional harm to those ecosystems. Conversely, if you assume the data gap and you say, ok we’re just going to cut it out at the beginning of the plan, then you’re not doing the analysis through the rest of the plan as to whether you might be impacting those ecosystems. So the precautionary principle is important because if you exclude important beneficial users early in the plan, then the whole plan ignores impacts to those beneficial users and harm can be happening to them. Where you don’t know, call it potential, you don’t have to commit to calling it an actual, and then do the work, do the monitoring to verify and fill those data gaps over the next five years so that in 2025, 2027, when the next plans come in, you probably will have better data and at that point, be able to make a better decision about actual groundwater dependency.”
Question: Sandi, you say if you were uncertain about whether an area is a GDE or not, keep it in. So say you have a situation where the structure is set, yes this is a GDE, now the question is, is it at risk or not? You have uncertainty – maybe it’s scenario uncertainty or maybe it’s being driven by uncertainty in the climate change information. How do you deal with that uncertainty and to how much do you err on the side of conservancy and protection?
“It’s up to local discretion, but I think that sort of getting into understanding more of what the specifics are of that GDE would be helpful here,” said Sandi Matsumoto. “It will depend on what the species of that particular area are and what their groundwater needs are, and that can help you narrow what the range of needs might be for those specific species to sustain them over time. Where there’s not information, I think there are many ways to be monitoring impacts. You can use even ecological and biological monitoring in this respect of looking at what’s happening on the surface to, for example, the riparian stand that’s in that area, and then comparing that to what the groundwater conditions look like.”
“I think it’s having multiple ways of diagnosing what the impacts are and adaptively managing over time, based on the incoming information,” Ms. Matsumoto said. “It’s having the adaptive loop. There’s always a cost-benefit decision to be made there, and it depends on if there are, for example, threatened and endangered species; I think that argues for a higher level of caution than something that might be more degraded and smaller and less functional. So one of the recommendations we make in the guidance is to look at each of the GDEs and value them. How important are they, how important are the species there, and how important is sustaining that ecosystem, because that can then help you in subsequent steps deciding how much to err on the side of caution in treatment through the subsequent steps in the plan.”
“Where I’m looking at uncertainty is in the sustainable management criteria, specifically the minimum thresholds and measurable objectives,” said Jennifer Clary. “One thing we’ve gone back and forth about in the CV-SALTS process is, you can’t try to control nitrates in groundwater, you can’t say, oh we’re getting close to ten so let’s put the brakes on now, because you don’t really know enough about the aquifer to know how to do that or what impact it is going to have, so really understanding what a buffer zone would look like in your sustainable management criteria is really important.”
Question: How can GSAs that are preparing these 2022 plans proactively address some of the interests and needs of the beneficial users you’ve identified in your presentation, disadvantaged communities, small drinking water users, environmental users?
“If we can take lessons from the 2020 plans, it was if beneficial users or interested stakeholders weren’t identified from the beginning, that seemed to carry through the plan,” said Samantha Arthur. “So I think for folks who preparing 2022 plans, there’s an opportunity to really do robust stakeholder engagement. I think a lot of that is actually integrating these stakeholder groups into the governance structures. For GSAs, whether its boards or advisory committees, that that sets inclusion from the beginning that then carries through the GSP and we don’t see as many of those shortcomings that we saw.”
“You also need to level the playing field because just including a representative of disadvantaged communities on a governing board does not necessarily ensure that they are able to participate fully, because you actually need to have a lot of technical knowledge and understanding to really understand and respond to the avalanche of information you’re being provided,” said Jennifer Clary. “Representatives of larger entities such as ag districts or counties of cities are more likely to have that expertise on hand, so providing technical assistance is part of representation.”
“I would also say that engaging underrepresented communities, a significant amount of that has been done by NGOs over the last few years and a lot of funding came from DWR to do that and that funding is no longer available, so I hope that GSPs are really seriously thinking about how they maintain that engagement in the absence of either support for those NGOs, or how they are going to pick it up themselves,” said Ms. Clary.
Question: In terms of the challenges you saw in reviewing the GSPs, what are some of the things that might make the work easier for reviewing GSPs that are due in 2022?
“For me, the easy one is go back to the basics and show your work, and make transparent where the decisions are being made and why,” said Sandi Matsumoto. “If, for example, in the water budget, you’re lumping managed wetlands and native habitats into something, pull it out and just show it separately so we know that it has been addressed, because some of the challenges we had were not being able to understand when the GSA doing the work and considering the things that we care about versus when they were being ignored.”