The case of the Curious CASGEM data

“A nation can survive its fools, and even the ambitious. But it cannot survive treason from
within. An enemy at the gates is less formidable, for he is known and carries his banner openly.  But the traitor moves amongst those within the gate freely, his sly whispers rustling through all the alleys, heard in the very halls of government itself. For the traitor appears not a traitor; he speaks in accents familiar to his victims, and he wears their face and their arguments, he appeals to the baseness that lies deep in the hearts of all men. He rots the soul of a nation, he works secretly and unknown in the night to undermine the pillars of the city, he infects the body politic so that it can no longer resist. A murderer is less to fear.”

~~ Marcus Tullius Cicero~~

San Luis Obispo County has 22 groundwater basins, all currently managed by the County Flood Control District. The three largest are listed by the California State Groundwater Elevation Monitoring (CASGEM) Basin Prioritization Process dated June, 2014 as requiring Groundwater Sustainability Agencies (GSA) formation. The San Luis Obispo Valley Basin, a medium priority basin at 19.5 score, is currently in overdraft. The Los Osos basin is listed as a high priority basin at 22.0 because of salt water intrusion. The largest basin in the county, the Paso Robles Groundwater Basin (PRGWB) is listed as potentially of the “most concern” because of the highest priority basin ranking score of 23.3.

Currently the county through its AB 3030 Groundwater Management District serves as a GSA for all three basins. Only the PRGWB, primarily at the instigation of the wine industry and the large cities and purveyors in the basin (who collective consume over 90% of the groundwater in the basin) has the dubious distinction of the only groundwater basin in the entire State subject to special legislation, AB 2453, crafted specifically to manage it. In this time of drought you would think that all this special interest by even the state legislature in the Paso Robles Groundwater Basin (PRGWB) and singling it out for special management must be because it is in terrible condition and on the verge of collapse.

You would be wrong.

Table 1 CASGEM data for the San Luis Obispo largest aquifers.

First take a close look at Table 1 CASGEM data for the San Luis Obispo largest aquifers.  Data shown is for the three largest San Luis Obispo Basins, as well as the Salinas Valley portion of the basin (3-4.05) just North of the Paso Robles Groundwater Basin (3.4.06). Based upon the CASGEM data, if population data is removed and the scores are calculated based only on water issues, the Paso Robles Groundwater Basin rates a “14.3” ranking score. The lowest ranking of all the basins. In comparison, the Los Osos Valley Aquifer, a high priority basin, still rates a 20.0 ranking, clearly a high priority basin score. The San Luis Obispo Valley Aquifer, a medium priority basin technically in overdraft, rates a 17.5 ranking score. Both basins incidentally have higher population densities.

So what pushes the PRGWB into high priority? It is population related data. Ignore “Population Growth” and “Other Information,” and if just water use issues are the main ranking consideration, the PRGWB would be ranked barely as a medium priority basin, not a high priority basin. If fact, we will show below why it should be ranked as a low priority basin.

How does the PRGWB go from lowest ranked to highest in San Luis Obispo? Easy, add in the population related data and suddenly the PRGWB is magically transformed from barely a medium priority to a high priority basin. Population growth concerns is ranked a “4” in the CASGEM data and the passage of the Urgency Ordinance is ranked a “5” adding a “9” to the to the overall ranking. This pushed the overall PRGWB ranking up to 23, making it a high priority basin.

This makes no sense. Remember The PRGWB is is a basin of about 900 square miles (Bulletin 118 boundaries) with a population density of approximately 60 people per square mile including Atascadero and Templeton. These two major residential areas are petitioning to be removed from the PRGWB because they claim the Atascadero sub-basin (area size 14,577 acres, about 23 square miles, source March 2010 Fugro Study) does not even have a hydrological connection with the PRGWB. If they are separated as requested, the population density for the PRGWB will drop even further into the mid 40s people per square mile. At 50 people per square mile or less CASGEM would not even rank the basin if there was not a concentrated population center of over 25,000 people i.e. the City of Paso Robles, in the basin.

Why does the PRGWB have a ranking score of “4” for population growth? The public data submitted for the PRGWB made an assumption that there was a projected growth in the basin of 137% by 2030. This is just plain flat wrong. In the county area of the basin which only has a population of about 8,000 people, the Urgency Ordinance (which we discuss below), which may soon become permanent, severely restricts development. In fact, because of offset requirements, new growth is zero.

This leaves only the city of Paso Robles as a future population driver, assuming Atascadero and Templeton are in a separate sub-basin as they argue. The current population of Paso Robles is approximately 30,000 with an expected build-out of 44,000 people by the year 2045. Even assuming steady growth (the city’s growth is actually flat right now) the city would only add in 7,000 more people by 2030 when total build out is reached. That is a 23% increase in population. Therefore, according to Table 5. Data Component Ranking Ranges for Population Growth in the CASGEM Basin Prioritization Process document, a growth of less than 100% should be scored “0.” Even if Atascadero and Templeton were added back to the projected growth (Templeton has a water hook up waiting list and Atascadero’s projected annual growth rate is 1.25% % according to the LAFCO document City of Atascadero Adopted Sphere of Influenece Update Municpal Service Review Sept. 15th, 2011) growth would still be less far less than 100%.

When asked where that magic 137% growth projection number came from, a CASGEM Senior Engineering Geologist could not answer, he assumed it came from the finance department. In fact, the CASGEM document confirms that the data is indeed based on 2010 census data and 2030 population growth projections generated by the Department of Finance and compiled by DWR’s demographic staff in the Division of Statewide Integrated Water Management. The document states that confidence in the data is “so high” it was not verified or weighted in any manner… Really?

Next, the “Other Considerations” rank scored a “5” in the CASGEM data… because of the passage of the Urgency Ordinance? This is a result that makes absolutely no sense at all. This category is usually reserved for adverse impacts on local habitat and local stream flows. The urgency ordinance is none of these.

The Urgency Ordinance and it proposed follow on permanent version is a heavy handed draconian ordinance that has effectively stopped all current and future growth – as well as any new net development of existing facilities for that matter, in the county portion of the basin. The whole rational for the passage of the ordinance is to conserve water use. From the view point of groundwater use and sustainability in the CASGEM ranking this should be a positive pro-active action and certainly does not merit a “5” score. It should be a “0” score since it effectively caps growth and water usage. This action lowers concern about future sustainability, not raises it. In fact, the prioritization process document states for other impacts “a negative ranking value of up to ‐5 is also allowed, as appropriate, to help rectify known issues associated with basin‐specific data relating to components one through six.” Freezing growth in the basin surely should have been a mitigating impact, not a maximum negative impact on sustainability.

It also follows if population growth is a concern, then passage of an ordinance to restrict groundwater use and freeze it at present levels to stop further growth should not be scored at the highest level of concern. In fact, it totally contradicts the population growth projection scoring and merits a negative offset value as allowed by the scoring process. When this discrepancy was pointed out to the CASGEM Senior Engineering Geologist, his rely was “well some of the data is somewhat arbitrary.”

If this was just an intellectual exercise, that would be OK. But a whole new intrusive law, the Sustainable Groundwater Management Act (SGMA -aka “sigma”) is based upon this data. This law will disrupt thousands of lives and businesses in the basin and cost millions of dollars in regulation fees and taxes. “Somewhat arbitrary” is an unacceptable answer. To attempt to negate its importance by characterizing it as casually “arbitrary” is unprofessional and devious.

Going back to just the water related data, we need to examine another curious data set, item 7 “Impacts” which is scored a “4” because of Nitrate and TDS impacts on groundwater. This is an unexpected result because the recently published (2014) San Luis Obispo County document “Appendix L San Luis Obispo County Groundwater Basins,” the Paso Robles Groundwater basin was rated as “generally good.” Contrast this with the San Luis Obispo Valley Basin (SLOVB) aquifer which is described as having known water quality issues (two high production wells were shut down due to high nitrates). Yet, for the SLOVB, the CASGEN ranking for item 7 “impact” is scored a “3” – lower than the PRGWB.

The Bulletin 118 Groundwater Basin Descriptions has some nitrate contamination information. For Basin 3-4.05 the extension of the PGRWB basin around King City the “Water Quality in Public Wells” table shows the result of 12 public wells were tested for nitrates. There were six wells found with a nitrate concentration above a Maximum Contaminant Level (MCL). In Basin 3-4.06, the Paso Robles subbasin, 58 pubic wells were tested for nitrates, only four were found with a nitrate concentration above a Maximum Contaminant Level.

Table 2. CASGEM data for all the medium and low priority Central Coast Aquifers

There is also current well data available on the website On that site listed well data for basin 3-4.05, the extension of the PGRWB basin around King City, has nitrate values greatly exceeding the listed values in basin 3-4.06, the PRGWB. This is not surprising given the intensity of agriculture in the Salinas Valley. Yet, the CASGEN data for basin 3-4.05 it is scored a “1” rank value.

The geotracker website also indicates that the nitrate values in the SLOVB also scored lower than the PRGWB in the CASGEM ranking, are in actuality much higher than the PRGWB, yet nitrates and known water quality issue for that basin are not even listed in the impacts for the SLOVB in the CASGEM ranking data. At the highest, the PRGWB basin should be scored no higher than a “1” like basin 3-4.05.

For a comparison of the PRGWB to other the medium priority and low priority basins, Table 2. CASGEM data for all the medium and low priority Central Coast Aquifers, shows the CASGM data for medium and low priority aquifers on the Central Coast. The top line is the Paso Robles Groundwater Basin as a reference.

The groundwater related data was averaged for each basin type and the results displayed at the bottom of Table 2. When the “curious” outlying data is removed, the PRGWB scores a rank of 11 which is below 13.2, the upper cutoff for a low priority basin. It is certainly not a high priority basin, and if real data was used, not even a medium priority basin.

Just in case you were wondering, no, there is no appeal process to the CASGEM ranking. DWR is now compiling data for the next release scheduled for 2017. There are no published hearing dates as of yet and how an interested citizen can participate in the process is not clear. No doubt the new data will be even more “curious.”

It should be evident that the PRGWB has been targeted for inclusion in SGMA regulation, reality be damned.

So the question is: Why is the least troubled basin in the county, and arguably the best managed of all the larger basins under such scrutiny and subject to AB 2453, special legislation written with the sole purpose of needlessly taking water rights away from the residents of the basin? What makes the PRGWB so special”

It has water stupid!

Yes, the PRGWB truly is a “High Priority Basin” but for different reasons. The CASGEN data clearly indicates that the PRGWB has water. And, unlike the other basins the PRGWB also has lots of potential storage space for water banking with the State Water Project (SWP) Coastal Pipeline conveniently passing through it. The only problem, the SWP pipeline is not yet connected to the PRGWB. But, there are plans underway to change that.

From the Paso Robles Groundwater Subbasin Water Banking Feasibility Study Final Report (2008):

The San Luis Obispo County Integrated Regional Water Management Plan (IRWM Plan) identified numerous opportunities that could improve the water supply reliability of San Luis Obispo County. One of the opportunities identified for investigation was banking water in the Paso Robles Groundwater Basin (Basin). This was considered a high priority project by the County with much potential because the Basin is the largest in the County and the Coastal Branch of the State Water Project (SWP) enters the County adjacent to the Basin. These two features, along with the County’s unused allocation of SWP water, led local water leaders to want to explore the feasibility of banking water in the Basin for the benefit of County residents.

Two things of concern standout in that statement: “local water leaders”  and  “for the benefit of County residents.”  The “local water leaders” are no doubt the perennial “stakeholder groups” of conflicted individuals and organizations that seem to be appointed to every water board that affects the Paso Robles Basin, The same individuals on the Paso Robles Basin Advisory Committee (PRBAC) that could not bring themselves to sign disclosure statements about any potential conflicts of interests and even altered the official minutes to remove any reference that the subject was even brought up.

And of course “County residents” are not the same as the PRGWB overlying property owners, the primary water rights holders who are in danger of having their water rights stolen by the “local water leaders.” It also ignores the fact that 90% of the coastal branch of the pipeline is owned by Santa Barbara County, not San Luis Obispo County. Water in that pipeline is destined to be moved outside the county because banked water, even “in lieu” which is in reality native water under a different name, is owned by the recharge district and not subject to any export ordinance.

Powerful political forces are maneuvering to appropriate the basin from its rightful owners and integrate it into the great California Water Ponzi scheme otherwise known as the State Water Project (SWP). To add insult to injury, the county with their proposed AB 2453 district expects the residents of the basin to pay for the facilities to pump the basin dry. The San Luis Obispo Board of Supervisors knows this and at least a few board members are complicit in this. No doubt that is why they are pushed the Local Agency Formation Commission (LAFCO) to pass the AB 2453 application before the public catches on to the their game.

What you need to know is, contrary to the male supervisors’ Cassandra hand-wringing, data manipulation, and dire predictions of impending doom if the residents don’t give up their water rights to the supervisors’ AB 2453 district, the PRGWB is not in serious condition now. But it will be if an AB 2453 water district is approved and the county and SWP move in.

Finally, there is the “curious” contemporaneous timing of this along with: the arrival of the duplicitous leadership of the faux grassroots Pro Water Equity and their group of “useful idiots;” the rise of their fellow travelers PRAAGS -the “amen chorus” of the largest water law firms specializing in representing the big water purveyors; the passage of the County Urgency Ordinance on the basis of eight mythical dry wells and fudged water use data; and finally, in the midst of all this “terrible water crisis,” the “camping” of the water barons and their “smart money” along that “convenient” SWP coastal pipeline. Coincidence? We think not.

As individuals residents in the PRGWB, there is not much you can do alone to stop this. It has been wired from the top down. There is only one real remedy left, Adjudication and the Courts. If you have not already joined the 500 and growing members of the Protect Our Water Rights (POWR) group, the largest landowner group in the PRGWB, what are you waiting for? Even you PRAAGS and Pro Water Equity members who were tricked into thinking your organizations were honest brokers, join before it is too late for you and the basin.



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