by Kristin Dobbin
Small Disadvantaged Communities (DACs), or DACs with less than 10,000 people, have long been disproportionately affected by California’s water management woes such as groundwater overdraft and pollution. Now, new research from the UC Davis Center for Environmental Policy and Behavior shows that the majority of small DACs are not participating in the Groundwater Sustainability Agencies (GSAs) formed to address them.
In 2014, California passed the Sustainable Groundwater Management Act (SGMA). Under SGMA, 127 high- and medium-priority groundwater basins were required to form Groundwater Sustainability Agencies (GSAs) by June 30, 2017. Now, GSAs have until January 2020 or 2022, depending on their basin condition, to develop Groundwater Sustainability Plans (GSPs). Throughout the process, GSAs have a responsibility to “consider the interests of beneficial uses and users,” specifically including DACs, which California defines as communities where the average Median Household Income is less than 80% of the state’s average.
How or if this will happen, however, is an important policy and research consideration extending beyond just SGMA. SGMA’s closest cousin in the state, the Integrated Regional Watershed Management (IRWM) program, has been criticized for not meeting the needs of small DACs. As a result, under Proposition 84 (2006), the state invested more than $2.5 million in DAC pilot studies; Proposition 1 (2014) includes $51 million in funding for DAC involvement in the IRWM program.
A spatial analysis identified small DACs intersecting one or more exclusive GSAs. GSA formation documents from the Department of Water Resources’ (DWR) SGMA portal were then used to analyze how small DACs are integrated into governance. Our analysis reveals three key findings.
First, the SGMA process will impact many of the state’s small DACs. 45% (243 of 545) of small DACs in the state intersect one or more GSAs. Moreover, a similar percentage of GSAs, 41% (109 of 269), intersect one or more small DAC. For example, the Tulare Lake hydrologic region has 81 small DACs intersecting 26 different exclusive GSAs, more than any other hydrologic region (Figure 1).
Second, the prevalence of small DACs was not well accounted for in the initial interested parties lists submitted to DWR despite the requirement of Water Code Section 10723.8 to include them. Overall, only 55% of the small DACs intersecting exclusive GSAs were identified anywhere in interested parties lists submitted. Only 51% of GSAs correctly identified all the small DACs in their boundaries. 23% identified none of the small DACs in their boundaries. Figure 2 provides an example of an interested parties list submitted to DWR. While the GSA’s list claims that there are no DACs known at this time, according to DWR’s publicly available DAC mapping tool, this particular GSA contains eight small DACs.
Third, the vast majority of small DACs are not formally participating in GSA governance. 25% (27 of 109) of GSAs with small DACs have small DAC members and 28% (30 of 109) have small DAC board members. Figure 3 shows how participation varies by hydrologic region. Participation rates also vary by the incorporation status of the community. While 47% (15 of 32) incorporated small DACs are members of their GSA and 53% (17 of 32) are board members, only 10% (22 of 211) of unincorporated small DACs are members of their GSAs and only 12% (25 of 211) are board members.
While GSA and board membership are not the only ways that DACs can or do participate in SGMA, these numbers, taken together with the 45% of small DACs that were not listed anywhere on their respective interested parties lists, calls into question the participatory and inclusive nature of the SGMA process thus far. SGMA, like IRWM before it, poses challenges in representing these already marginalized groundwater users. Understanding these challenges, and what can and should be done about them, are important areas for future research as GSAs dive head first into writing their GSPs.
Kristin Dobbin is a PhD student in Ecology at UC Davis studying regional water management and drinking water disparities in California. Many thanks to Mark Lubell and Amanda Fencl for their review and edits.
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