1.The District must recognize that the major water users will not take
action until faced with what they see as an absolute necessity. The major
action of the district must be placement of a limit on withdrawals by each
holder of a CUP, together with a date this becomes effective.
2. The District must also recognize that aquifers are being pumped beyond
the current natural recharge, that damage to streams, lakes, vegetation
and springs has been and is occurring, and further that it is the responsibility
of the District to stop further damage and to correct past damage.
3. The District must further recognize that it either lacks or does
not use the tools needed to show the water allocation for the items mentioned
in 2. The district does not have a water budget analysis system. It's response
to a drought situation is to state that water consumption increases, not
to require reduction in consumption. And the District persist in the position
that it it is impossible to determine recharge, when the models it does
use calculate this for each model cell under at least some condition, and
simple addition
4. The chart, Fig.1, is much too generalized. Example in Resource Development:
"Aquifer recharge enhancement" is a goal, not a specific something which
can be planned, costed. scheduled and completed. A possible and likely
item under this goal is "install low-flow control gate in listed canals".
The first example in Supply Development assumes that more water can be
taken from the already over-pumped aquifer. And the remaining items do
nothing to develop supply.
5. We must submit that the content of this document does not meet the
District's legal responsibilities, and that it must be completely redone.