CSPA Comments on Groundwater Workplan Concept Paper

On 18 December 2013, CSPA submitted comments on the State Water Resources Control Board’s draft Groundwater Workplan Concept Paper.  While generally supporting the papers five management elements, CSPA pointed out that water quality must be measured and the results publically reported.  Further, the State Board was urged to develop standards and specific conditions for water permits and licenses that propose to divert surface water to groundwater storage, including measurement of the amount of water diverted to groundwater and the amount subsequently pumped for beneficial use.  Permit conditions should protect groundwater levels where overdraft exists and the State Board should make findings that diversion of surface water to groundwater in areas where persistent overdraft is not corrected constitutes a waste and unreasonable use of water and an unreasonable method of diversion.

CSPA Comments on Groundwater Concept Paper