CA WATER COMMISSION: Update on SGMA Implementation

At the February meeting of the California Water Commission, Tim Godwin, Supervising Engineering Geologist at California Department of Water Resources, provided an update on SGMA implementation, including an overview of the groundwater sustainability plans that DWR has reviewed to date and the approach and timeline for reviewing the plans submitted in January 2022.

With the current drought conditions, Mr. Godwin said that all facets of the Department of Water Resources are looking for ways to offset the conditions and help to manage the state’s water resources so we can keep moving forward.  This is especially important for SGMA and groundwater management as the drought highlights the need for sustainable groundwater management.  The graphic shows the general decline in groundwater levels over the last 20 years, which highlights the need to manage groundwater to maintain and sustain the resource into the future. 

Bulletin 118, California’s groundwater, identifies 515 alluvial groundwater basins across the state.  A subsequent process specified in the SGMA legislation identified 94 high and medium priority basins subject to SGMA.  Those basins were required to develop and establish groundwater sustainability agencies (GSAs)  and develop groundwater sustainability plans (GSPs). 

Of those 94 basins, 21 were identified as critically overdrafted.  Those basins had long-term known declines in groundwater levels or other significant groundwater impacts.  As a result, SGMA required the critically overdrafted groundwater basins to submit their groundwater sustainability plans to the Department for review by January 2020.

Mr. Godwin noted the significant milestone just achieved for SGMA implementation.  “All of these basins that were required to develop GSPs have submitted them to the Department at this time,” he said.  “All of these new public agencies have committed to managing their groundwater sustainably at the local level, which is a tremendous success and very much in line with what SGMA intended.  So I want to commend those local agencies for taking those significant strides to establish themselves as an agency, but also to make those hard decisions about what sustainability is in their basin and how they’re going to achieve it.  So it is a tremendous milestone.  It’s also a pivot point for the Department where we’re looking towards how do we assist agencies in implementation.”

Evaluation of the 2020 GSPs

When evaluating the plans, there are three possible outcomes:

  • The Department can approve the plan;
  • The Department can determine the plan is incomplete and give the GSA(s) 180 days to correct the deficiencies; or
  • The Department can find the plan inadequate and not in substantial compliance with the GSP regulations and SGMA, potentially triggering intervention by the State Water Board.

The Department had two years to review the plans for the critically overdrafted basins; those assessments were recently released.  Eight of the twenty plans submitted in January of 2022 were approved.  However, Mr. Godwin noted that while the Department approved those plans, they also provided recommended corrective actions for the agencies to work on to better align with the intent and requirements of SGMA.

SGMA provides 20 years for the GSAs to reach their sustainability goal, with updates to the plans occurring no less frequently than every five years.

These basins, identified here in green, all received an approved determination but also have things to work on locally,” said Mr. Godwin.  “They continue to implement their plans and work on those conditions.”

The remaining plans submitted in January of 2022 were determined to be incomplete, meaning they had deficiencies that didn’t quite align with the GSP regulations and SGMA.  The agencies now have 180 days to correct the deficiencies. 

We’ve been meeting with these agencies to make sure that they understand the deficiencies, and we are working with them to create a pathway forward to addressing the deficiencies within the timeline,” said Mr. Godwin.  “We continue to meet with these agencies and continue to provide our assistance through data and other sources to meet those requirements and get back on track.  Hopefully, within 180 days, by mid-July, those plans will return to the Department for evaluation again.”

Common themes from GSP evaluations

With the plans found to be incomplete, Mr. Godwin noted that most of them addressed overdraft head-on.

 “They acknowledged that they have been overdrafting the basin for quite some time and that changes were necessary to eliminate the overdraft, a core fundamental action identified in SGMA,” he said.  “However, SGMA also states that not only are they to eliminate overdraft, but they are also to address six undesirable results: the chronic lowering of groundwater levels, reductions in groundwater storage, seawater intrusion, degraded water quality, land subsidence, and the depletion of interconnected streams associated with pumping.”

There are layers of complexity here,” he continued.  “While you can say that you’ve eliminated overdraft, there still may be conditions occurring in the basin that are determined to be significant and unreasonable with respect to any one of these sustainability indicators.”

Another issue was how all the beneficial uses and users within the basin were considered with respect to the sustainability indicators.  “That’s a real challenge,” said Mr. Godwin.  “There are a lot of different users within the basin.  So  we’ve highlighted those and called on the agencies to reevaluate how those beneficial uses and users may be impacted by the GSP implementation and asked them to reconsider how they may act to address some of those issues.

One of the Department’s significant concerns is the impact on the domestic drinking water supply as a beneficial use.  Some plans have identified criteria that could potentially allow for water levels to decline in a way that could cause wells to go dry within basins at a significant level, so there could be significant dewatering of these domestic wells.

We’ve asked them to evaluate that further and articulate what those impacts could be, where and when they could occur within these basins, and to talk about how their projects and actions that they have proposed may address some of these impacts,” he said.  “We’re looking for a much higher level of communication in terms of how the plan will be implemented and how it is respective of all beneficial uses and users in the basin.”

SGMA specifically calls for the reduction or elimination of land subsidence, which occurs when excessive pumping causes the collapse of clay layers within the aquifer, causing the land surface to subside and decrease in elevation.

What SGMA calls for is the identification and analysis of those significant land surface uses and the infrastructure associated with them that may be affected by subsidence,” he said.  “So those basins that have been affected by subsidence, we’ve asked them to take a closer look at that and to evaluate all of the specific surface uses and infrastructure that may be affected by this condition and reevaluate how that may affect the beneficial uses and surface uses in the area.”

The depletion of interconnected surface waters is also a significant challenge for all of the agencies.  Mr. Godwin acknowledged that the analysis is still cutting edge to evaluate how pumping may affect the streams and lose water to the system.

Accounting for that is specifically identified in SGMA and the groundwater GSP regulations.  They must identify not only where but what quantities are being depleted from streams associated with pumping in their basin,” he said.  “So we’ve been working with all the basins to refine the process and meet the statute. … The Department is actively working on providing recommendations and guidance and tools and data to support those types of analysis.”

Coordination is a challenge in the basins with multiple GSPs responsible for covering the basin.  SGMA and the GSP regulations require that the same data and methodologies for analyzing the basin be used across the basin, so it’s ‘apples to apples’ when comparing one region within the basin to another.

This is a substantial challenge for many folks because they do have an understanding of their groundwater basin with the way they analyze it, but the neighbor may not analyze it the same way,” he said.  “Are those numbers comparable?  And did they respectively poll the basin?  So these are challenges that we’ve asked people to go back and take a look at.”

Water quality is also a concern; the Department is asking them to look at how water quality is distributed across the basin and how their project and management actions affect it.

In general, one of the challenges for multiple GSP basins is the lack of coordination; even within small single GSP basins, coordination is still a challenge,” Mr. Godwin said.  “So we’re asking these GSAs, again, newly formed agencies, to communicate very closely to one another to address the conditions across the basin.  So it’s a tall ask, but we are working with them on those solutions.”

Many agencies have data gaps and have acknowledged that they don’t have all the information needed to make informed decisions.  So the Department has asked them to address those data gaps and identify a plan to fill those gaps that will then inform their plan moving forward.

The Department is also encouraging and providing assistance to continue engaging with the stakeholders in the basin and incorporating those various beneficial use voices into their governance and decision-making process as they make those critical decisions about locally defined sustainability.

Another challenge is implementing the projects and management actions.  “These aren’t cheap projects and management actions,” Mr. Godwin said.  “Usually, folks are proposing significant actions to improve the supply side rather than address the demand reduction side.  So they’d rather add more water to it than tell people that they have to pump less.  And we understand that desire.  That has significant economic and social impacts in these regions.  So we’re working hard to provide data and information as to how best we can enhance and incorporate additional supply-side augmentation for them.”

The timing of the drought has made it more challenging, just as the agencies are getting started on implementing their plans.  There isn’t much surface water supply available, so hard choices are being made about how best to avoid undesirable results and maintain the status quo.  

“There’s some adjustment going on, and the adaptive process embedded in SGMA is intended to provide a way to manage and work through these things over the next 20 years as they implement.  So adjustments are likely.”

2022 GSP submittals and alternative reports

All of the remaining high- and medium-priority basins submitted their plans by January 31.  Those plans are available on the Department’s SGMA portal and are open for public comment.  Folks are encouraged to submit their comments and concerns with the submitted plans.

Those basins that submitted alternative plans are now providing their required 5-year update, which were due January 1.  The Department will be reviewing the updates to see what progress has been made in addressing the recommended corrective actions that the Department provided and how they are implementing new projects and actions in their basins to maintain their sustainability.

The SGMA portal has information about the groundwater sustainability agencies, the groundwater sustainability plans, the alternative plans, how basin boundaries have been modified, and how the basins may have changed over time.  Visit the portal here:


Moving forward, the determinations for the 2020 GSPs were issued in January of 2022.  Twelve plans have been determined to be incomplete; those GSAs have 180 days (or until late July) to address those deficiencies and resubmit their plans to the Department.

The Department received 65 GSPs from the remaining 63 basins in January of 2022.  Mr. Godwin noted that while many of the 2020 plan submittals had multiple GSPs in their basins, there was a lot less of the multi-GSP structure in the plans submitted in January of 2022.   Those basins with approved alternative plans have recently submitted their updates.  The Department has until January of 2024 to evaluate the plans and review the alternative reports.   The first updates to the 2020 GSPs will be due in January of 2025.

Mr. Godwin also noted that the agencies are also required to submit annual reports.

Technical, planning, and financial assistance

Mr. Godwin then highlighted some of the Department’s technical assistance programs:

  • Accessing Groundwater Data and Tools Webinar: A webinar that demonstrates how to access and use the tools and data the Department is providing.
  • Land Subsidence Data-Now Available Quarterly: The Department is working to improve the understanding of land subsidence conditions, what’s triggering them, and what the current actions are. So the Department will be providing InSAR-based land subsidence data quarterly on the SGMA data viewer and the CNRA open data website.
  • Airborne Electromagnetic (AEM) Surveys: The Department is imaging all of the high and medium priority basins to understand better the geology structure that controls groundwater flow.  This data will help local agencies understand the geology controlling groundwater so they can better inform their project and management decisions.
  • Technical Support Services: This includes new monitoring well installation as well as borehole camera surveys and downhole cameras for basins that can evaluate wells and help agencies better understand the conditions.
  • New Efforts on Accounting & Water Trading: The Department is working with the California Data Consortium and the Environmental Defense Fund to develop a water accounting and water trading tool. The tool was piloted early on by the Rosedale Rio Bravo Water Storage District in Kern County.  It could be a valuable tool for folks to use to help them manage local groundwater trading.

DWR has several resources to support GSA outreach and engagement efforts:

Funding assistance:

  • Over the next three years, approximately $350 million is available for updating GSPs, filling data gaps, additional outreach and engagement, and project development and implementation.
  • For more information, visit the SGM Funding Assistance webpage.


Commissioner Samantha Arthur asked about staffing.  How are you staffed to evaluate the 63 plans over the next two years?  Do you have the support that you need? 

With the staffing for our Sustainable Groundwater Management Office, the Department of Finance has provided ample opportunity for us to build out our team, and we are making significant progress in doing so,” Mr. Godwin said.  “We have grown a lot since the start of SGMA.  And while our first tranche of plans was challenging to work through; they are very complex plans – they are the first plans.  Just as the agencies are navigating how to write a plan, we are navigating how to evaluate a plan.  We have regulations to help us and guide us.  But there are a lot of in-between spaces that we had to work through to keep SGMA on track and moving forward.”

Our regional office staff also contributed to review of these plans, and we are also building out a lot more capacity at our headquarters office. … I’m optimistic that the degree of staffing we’ve been allowed is sufficient for us to manage this.  We’ve learned a lot as well as the GSAs.  And we’re implementing some changes to be moving through our reviews much more quickly.”

Commissioner Arthur asked how the coordination with the State Board and the Department of Fish and Wildlife is working.

We continue to coordinate with each of those agencies,” Mr. Godwin said.  “We’re in a little more close coordination with the State Board because of the statutory ask both of our agencies that, should a plan be determined to be inadequate at some point, we can transition that with the intent of getting that back into local control as rapidly as possible.  So we’ve been able to communicate our decisions to the State Board and help inform them as to what some of the deficiencies we’ve been seeing and how we see it playing out.  So that’s been helpful, I think, for their planning and understanding of how we’ve evaluated those plans.”

With the Department of Fish and Wildlife, we continue to coordinate on a number of fronts to understand just exactly what their concerns are with the plans,” he continued.  “They’ve provided specific public comments.  And I want to be very clear about that.  We’re being very clear that we want this to be very transparent.  And so they provided public comments through our comment process because really, it’s about the locals taking action and control of how this gets implemented into their plans and how they’re considering all those users.  So it’s been successful from a coordination standpoint. … The Department is taking a close look when we review the GSPs as to what those comments are saying, not only from our sister agencies but from the public as well.”

Commissioner Arthur asked, regarding the funding assistance, can you share some thoughts on how financial assistance can play a role in directing or supporting the more challenging steps of implementation?

We have a solicitation package out there already,” said Mr. Godwin.  “It is really about moving the needle and some of these big actions that agencies are looking at.  With our assessments meaning revising their plans, some of those big actions are getting projects going so they can start to offset domestic drinking water wells, or whatever action they need to address overdraft and keep on track for meeting their sustainability goal in 20 years.  It sounds like a long time, but it’s not in the context of implementing projects and actions that will change the direction of groundwater supplies moving forward.”

So we’re very focused on getting those monies out; the direction from the legislature was to get this money out for agencies to implement immediately, and we’ve done so.  But as we move forward, those incentivizing approaches are absolutely part of the puzzle.  Right now, our incentive drivers are in our assessments and guiding them to see what we’re asking them to work on—but moving forward, absolutely.  Our financial assistance branch, we work very closely with them.  And we will coordinate on in terms of how we incentivize those actions that will meet those needs within the basins that we see out there.”

Chair Teresa Alvarado asked about metrics to evaluate collaboration and stakeholder communication and engagement.  How are you validating that the public engagement is taking place?

This is a challenge in that the Act doesn’t call upon us to tell the agencies how to do governance and how to manage their basin, but we do recognize that as being a significant need,” said Mr. Godwin.  “So we’re calling upon them through our assessments and talking about how they’ve considered the beneficial users and users, and how they incorporated those comments.  These are requirements within the regulations for them to address. … We require reporting of how they’ve complied with public noticing and public meetings and how they prepared responses to comments.  Those are included in the portal, so there’s a lot of information in that document, such as what steps agencies have taken to engage with interested parties.  They are required to manage an interested parties list, for example, and they provide that as well.  So there are some pieces that we are very active on and trying to encourage that process.  But as far as a metric for us to evaluate the degree to which outreach occurred at the local level is not part of our review process.”

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