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Sjc-223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 SJC-223 1 THOMAS H. KEELING (SBN 114979) 2 FREEMAN FIRM 1818 Grand Canal Boulevard, Suite 4 3 Stockton, CA 95207 Telephone: (209) 474-1818 4 Facsimile: (209) 474-1245 5 Email: [email protected] 6 J. MARK MYLES (SBN 200823) Office of the County Counsel 7 County of San Joaquin 44 N. San Joaquin Street, Suite 679 8 Stockton, CA 95202-2931 9 Telephone: (209) 468-2980 Facsimile: (209) 468-0315 10 Email: [email protected] 11 Attorneys for Protestants County of San Joaquin, 12 San Joaquin County Flood Control and Water Conservation District, and 13 Mokelumne River Water and Power Authority 14 [ADDITIONAL COUNSEL LISTED ON FOLLOWING PAGE] 15 BEFORE THE 16 CALIFORNIA STATE WATER RESOURCES CONTROL BOARD 17 HEARING IN THE MATTER OF WRITTEN TESTIMONY OF JOHN LAMBIE, CALIFORNIA DEPARTMENT OF WATER P.E., P.G., C.E.G. 18 RESOURCES AND UNITED STATES BUREAU OF RECLAMATION 19 REQUEST FOR A CHANGE IN POINT OF (PART 2 CASE IN CHIEF) 20 DIVERSION FOR CALIFORNIA WATER FIX 21 22 23 24 25 26 27 ___________________________________________________________________________________________ 28 1 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF) SJC-223 1 JENNIFER SPALETTA (SBN 200032) SPALETTA LAW, PC 2 P.O. BOX 2660 LODI, CA 95241 3 Telephone: (209) 224-5568 4 Facsimile: (209) 224-5589 Email: [email protected] 5 Attorneys for Protestants County of San Joaquin, 6 San Joaquin County Flood Control and Water Conservation District, and 7 Mokelumne River Water and Power Authority 8 OSHA R. MESERVE (SBN 204240) 9 SOLURI MESERVE, A LAW CORPORATION 510 8 th Street 10 Sacramento, CA 95814 Telephone: (916) 455-7300 11 Facsimile: (916) 244-7300 12 Email: [email protected] 13 Attorneys for Protestant Local Agencies of the North Delta 14 15 16 17 18 19 20 21 22 23 24 25 26 27 ___________________________________________________________________________________________ 28 2 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF) SJC-223 1 WRITTEN TESTIMONY OF JOHN LAMBIE, P.E., C.E.G., C.W.R.E. 2 I. PROFESSIONAL BACKGROUND 3 4 Since 2006, I have served as the Principal Groundwater Hydrologist for E-PUR, LLC. I 5 hold an M.S. degree in Sediment Mechanics and a B.S. in Earth & Planetary Sciences, both 6 from the Massachusetts Institute of Technology (M.I.T.). I am a registered Professional Civil 7 Engineer in California. In addition, I am a Certified Engineering Geologist in California, and a 8 licensed Professional Geologist in California. 9 Over my 34-year career in groundwater and water resources consulting, I have acquired 10 specialized training in Groundwater Modeling, Data Statistics and Interpretation, and 11 Geographic Information Systems. As set forth in my Statement of Qualifications (SJC-222), I 12 have conducted numerous water resource studies, most of which focused on groundwater and 13 groundwater recharge. I have worked on a number of groundwater and water resource 14 projects in the area of the Delta since 2010 and therefore am generally familiar with water 15 resource issues of the area. I have examined pertinent data and reports for the region. My 16 Statement of Qualifications also includes information about publications and presentations for 17 which I was responsible, in whole or in part. 18 II. TESTIMONY 19 A. Summary of Findings 20 My testimony provides information regarding the effects on surface water to 21 groundwater interaction that would result from operation of the new diversions proposed on the 22 Sacramento River as part of the Delta Tunnels project (a.k.a. the CWF project) to serve the 23 State Water Project (SWP) and Central Valley Project (CVP). I have evaluated the effects of 24 operating the new proposed diversions on two groundwater subbasins defined by the State of 25 California Department of Water Resources (“DWR”) as the Sacramento Valley - South 26 American Groundwater Subbasin (5-021.65) and the San Joaquin Valley - Eastern San 27 28 ___________________________________________________________________________________________ 3 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF) SJC-223 1 Joaquin Groundwater Subbasin (5-022.01) (hereinafter referred to collectively as the 2 Subbasins). 3 SJC-224 depicts the outline of the two Subbasins as well as identifying the location of 4 the proposed new diversions and the reaches of the Sacramento River and Mokelumne Rivers 5 in which flow and river stage would be reduced from current and historic conditions if the Delta 6 Tunnels project is implemented as proposed. These two Subbasins are categorized by DWR 7 as high priority, in DWR’s CASGEM Groundwater Basin Prioritization. (See LAND-124, 8 CASGEM Basin Prioritization – North Central Region.) This high priority designation for each 9 of the Subbasins signifies that groundwater is relied upon heavily as a means of water supply. 10 It also signifies that all the requirements of the Sustainable Groundwater Management Act of 11 2014 (the SGMA, Water Code section 5200 et seq.) will apply to sustainable groundwater 12 management of these Subbasins, since both high-priority and medium priority groundwater 13 subbasins are subject to the SGMA. In addition, DWR Bulletin 118 - 2016 identifies the 14 Eastern San Joaquin Groundwater Subbasin as critically overdrafted. As defined in the SGMA, 15 “A basin is subject to critical overdraft when continuation of present water management 16 practices would probably result in significant adverse overdraft-related environmental, social, 17 or economic impacts.” 18 Furthermore, DWR has identified conditions of the groundwater levels in each of the 19 Subbasins as being both below river stage and below sea level. Exhibit SJC-225 depicts 20 DWR’s groundwater elevation data for the South American Groundwater Subbasin from Spring 21 2015 and their interpretation of that data by their elevation contouring and color-ramp mapping 22 of elevations. Exhibit SJC-225 depicts a groundwater basin that was in a deficit and depleted 23 condition when SGMA went in effect on January 1, 2015. (See also SJC-253 [Zone 40 24 groundwater contour map].) Exhibit SJC-226 depicts similarly DWR’s groundwater elevation 25 data for the Eastern San Joaquin Groundwater Subbasin from Spring 2015 and DWR’s 26 interpretation of that data by its own elevation contouring and color-ramp mapping of 27 28 ___________________________________________________________________________________________ 4 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF) SJC-223 1 groundwater elevations. Exhibit SJC-226 depicts a groundwater basin that was in deficit and 2 depleted when SGMA went in effect on January 1, 2015. 3 Exhibit SJC-227 provides a conceptual framework to illustrate the movement of surface 4 water to groundwater based upon the current and historic conditions documented by DWR. 5 Exhibit SJC-227 depicts the nature of the effect on groundwater recharge in the two Subbasins 6 that would result if the new diversions on the Sacramento River were to be constructed and 7 operated. As depicted in SJC-227, the groundwater elevations are below the river stage (as 8 has been the case for many years). This signifies that surface water is discharging to 9 groundwater at all times throughout the year. 10 When the surface water elevation, commonly referred to as the river stage, goes up and 11 down due to any of a number of factors, including tides, stormwater flows, or controlled water 12 releases from upstream storage, then the rate of surface water exfiltration goes up and down 13 with it. What SJC-227 depicts along the edges of the Sacramento River and Mokelumne River 14 is the chronic relative changes in river stage in the impacted reaches depicted in SJC-224 that 15 would occur with operation of the proposed Delta Tunnel diversion intakes. 16 This relative change in river stage is a key term. It signifies that by superimposing the 17 change in river flow due to the proposed new diversions on top of tidal changes, stormwater 18 flows, and controlled releases, that these diversions would cause relative reductions in surface 19 water exfiltration to groundwater recharge if the new project and its new diversions are 20 implemented. Lowering the flow volume by diverting water through the proposed intakes would 21 cause a corresponding lowering of the surface water elevation. This is depicted in SJC-227 as 22 a change in river stage on the Sacramento River downstream of the three proposed intakes 23 and on the Mokelumne River downstream of the Delta Cross Channel (the DCC) due to the 24 change in river stage in the depleted Sacramento River and river flow in the Sacramento River. 25 (Accord DWR-5 errata, slides 75-82,DWR 66, pp. 9-10 [discussing water level stage changes 26 as a result of the diversions].) 27 28 ___________________________________________________________________________________________ 5 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF) SJC-223 1 Lowering a river’s stage by even a very small amount can significantly reduce the 2 surface area of the river over which surface water can exfiltrate to groundwater. (See SJC-251, 3 USGS Circular 1139 “Groundwater and Surface Water A Single Resource,” pp. 9-10 4 [describing generally phenomena on the impacts of losing streams and streamflow stage on 5 surface water and groundwater interaction].) The surface area over which river water exfiltrates 6 to groundwater is the product of the wetted perimeter of the river by the length of the river 7 reach. The focus in this analysis was on the river reaches that would be impacted by a change 8 in river flow and stage as is quantified for each Subbasin. 9 The definition of the wetted perimeter is the circumference of the river in contact with its 10 bed and banks when measured in cross-section of the river.
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