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).
Figure 1. Small DACs and exclusive GSAs in the Tulare Lake Basin.
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.
Figure 2. A screenshot of the interested parties list from an exclusive GSA’s notification.
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.
Figure 3. GSAs with small DACs, small DAC members and small DAC board members by hydrologic region.
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.
Further Reading
Balazs, C., & M. Lubell. 2014. Social learning in an environmental justice context: a case study of integrated regional water management. Water Policy, 16(S2), 97-120.
Disadvantaged Communities Visioning Workshop December 3-5, 2014. Recommendations. 2015.
Dobbin, K. Research Brief: Small Disadvantaged Community Participation in Groundwater Sustainability Agencies. 2018. (English / Spanish).
Dobbin, K., J. Clary, L. Firestone and J. Christian-Smith. 2015. Collaborating for Success: Stakeholder engagement for Sustainable Groundwater Management Act implementation.
Feinstein L, Phurisamban R, Ford A, Tyler C and Crawford A (2017) Drought and Equity in California, Pacific Institute, Oakland, CA
Sad to think our great scientist and educational institutions can not see how much water is stored in CA and how much goes out the Bay. Even worse it no one can see or wants to see real solutions, like slowing the water leaving the bay to make the Delta more of a fresh water estuary but adding a shipping lock and a few tidally controlled louvers while keeping part of it open for fish and small boats. Or extending the Folsom South canal to Southern Delta to improve water and flow for fish and pumping.
Also many water extraction processes exist like WaterFX that can clean water using solar power or using water shafts to naturally create the pressure for membrane filtration and only pump up the cleaned water.
Ms. Dobbin:
Have you run across any maps of the disadvantaged communities that identifies surrounding city and special district (including water/irrigation district) boundaries? It might be useful to know close the studied communities are located to existing governments.
Phil Isenberg
PS: Good blog post. Keep it up!
Hi Mr. Isenberg – Yes I have, there are actually two. The DWR has a water agency GIS layer in their SGMA data viewer which shows water agency boundaries including water/irrigation districts. The Department of Public Health also has a Water Boundary tool which is just for drinking water district boundaries (including cities) which they have recently put a lot of work into updating and cleaning (which is what I used to identify potential surrogate representatives discussed in the linked research brief). There are also some coordinated efforts underway to clean and package that type of information or easier use in the SGMA process.
The Center for Regional Change at UC Davis recently came out with a study that did a spatial analysis of the proximity of DACs without safe drinking water to other compliant drinking water systems. While they were looking at a different question their finding’s that most DACs are extremely close to other drinking water systems would likely be similar to any analysis done for SGMA, in fact because there are so many non-drinking water water agencies like irrigation districts my guess is there would be even more overlap/proximity.
Though I think the report by Kristin has some merit and describes a problem, it isn’t complete. First off the analysis completely ignores the broader problem. That problem is the community’s stakeholders preparation for involvement in the issues. These communities by and large lack sophistication with “policy development”. Something even the best of us struggle with. Competing for SGMA’s attention in these communities are larger and he more personal issues of food and shelter, social concerns, fear of law enforcement and government, citizenship and others issues.
In the Kaweah Sub-basin we are trying mightily to reach out to these communities and are having little response. What are also working with non-profit agencies that have a face within the communities (Community Water Center, Self Help Enterprise, Leadership Council).. Those agencies have all received grant awards for SGMA water education. While GSA’s are tasked with developing policy with public input, educating these stakeholders and then getting input from those newly educated stakeholders on SGMA development prior to January 2020 is an insurmountable task.
Credit should be acknowledged as to what GSA’s are faced with, some thoughts on how the non-profits and the GSA’s can work together is probably a better analysis and beneficial blog address. As opposed to a narrow perspective on the issue.
Truly, there are substantial hurdles. To couch the problem so narrowly is symptomatic of the fear GSA’s are concerned with. We are concerned that we will be blamed for not involving stakeholders that, as far as outreach goes, we have spent and will spend, most of our time and dollars attempting to connect with and get input from. Our fear is that after this substantial effort they will wield the greatest political power on the basis of misunderstood problems and it will overturn the hard work being done to solve a severe problem we as a sub-basin face.
Hi Michael – Thanks so much for taking the time to share your thoughts. I one hundred percent agree with you that this research is far finished. This project was necessarily limited by the information available in the required GSA notifications. A lot more research is needed to understand the many challenges related to DAC engagement on all sides, many of which you mentioned in your comment. I expect that GSPs and their accompanying communications and engagement plans will provide more information. Even prior to that I am hoping to do a phase two of this project where I conduct interviews to better understand the gaps which will hopefully lead to some constructive recommendations (hopefully I can visit Kaweah when I do!). As an initial quantitative description of small DAC participation, I hope that this research underscores the fact that these challenges remain significant, despite state efforts to improve DAC involvement in water management, and that it will prompt future discussion and research so that GSAs and DACs alike can be better supported in this area.
West Kern Water District is in the process of correcting the error of not listing our disadvantaged communities in our GSA filing. It was simply a mistake made in processing our application. Having said that, I would like to point out that the Board members for our GSA are elected by people living in these disadvantaged communities. In fact, several of the Board members either live within these disadvantage communities or have family and friends living within them. In spite of the non-listing in our application, there is involvement of these disadvantaged communities and a sensitivity to their needs. In closing, although our groundwater banking operations are located in a critically over drafted basin, the West Kern Water District has operated sustainably since the early 1970s by importing water to balance our groundwater pumping. For this reason, we expect there to be virtually no impact on our customers from the implementation of SGMA.
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