GSP Public Comments: Audubon Society
Last updated 7/5/2019 at 12:54pm
From: James A. Peugh, Conservation Chair, San Diego Audubon Society (SDAS)
To: Jim Bennett, County of San Diego Planning & Development
SDAS reviewed the Draft GSP for the Borrego Valley Basin to assess the treatment of groundwater dependent ecosystems and interconnected surface water systems as required by SGMA.
SDAS has an interest in sustainable groundwater management because many wildlife habitats and ecosystems rely on groundwater or interconnected surface water.
This letter will outline concerns we have with three topics discussed in the GSP: 1) Groundwater Dependent Ecosystems (GDE’s), 2) Beneficial Uses and Users of Groundwater, and 3) Depletions of Interconnected Surface Water Systems.
1 – There are three GDE’s described in the Plan: Coyote Creek, Palm Canyon, and Mesquite Bosque. Other GDE’s mentioned are Hellhole Palms. Tubb Canyon, and Glorietta Canyon, though there is no analysis of their ecological condition, past or present and their hydrological relationship, to the Subbasin. This appears to us to be a significant deficiency.
Please revise the GSP to include this information for all of the relevant GDEs and include information on the likely impacts of the lack of ground water sustainability on key species in each of these GDEs.
2 – Under SGMA, depletions of surface waters interconnected with water in the Subbasin that have significant and adverse impacts on beneficial users of surface waters constitute an undesirable result.
There are brief and inadequate descriptions of all three GDE’s in the Plan, The Least Bell’s Vireo is an endangered species with critical habitat on Coyote Creek, and there are numerous other species who should be identified as beneficial users of groundwater. Please perform an accounting of species and add Environmental Users to Table 2.1-7 (p. 2-26).
Full story in the June 27 issue of the Borrego Sun.