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 Water and Power Authority 14 [ADDITIONAL COUNSEL LISTED ON FOLLOWING PAGE] 15 BEFORE THE 16 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 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 as part of the Delta Tunnels project (a.k.a. the CWF project) to serve the 23 State Water Project (SWP) and (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 - South 26 American Groundwater Subbasin (5-021.65) and the - 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 (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. Thus, if the river stage is reduced 11 due to new diversions in the reach above it, then the wetted perimeter would be reduced 12 according to the geometry of the river’s cross-section. This is depicted by the USGS on page 13 10 of Exhibit SJC-251 as a general principle of stream stage rise and fall. Exhibit SJC-227 14 provides a conceptual depiction for this matter of the Sacramento River in cross-section 15 downstream of the proposed diversions; in that depiction one can see the reduction in the 16 wetted perimeter at the upper edges of the river bank in contact with river water. This same 17 type of relative change for the Mokelumne River stage and wetted perimeter is also depicted in 18 Exhibit SJC-227 downstream of the DCC where Mokelumne River flow and stage height are 19 affected by current and proposed CVP and SWP project operations, and where both the 20 Mokelumne River and its channels would be impacted by the new diversions to the 21 Delta Tunnels projects. The change in wetted perimeter over the reaches of the Sacramento 22 and Mokelumne Rivers that would occur as a result of the proposed new diversions would 23 substantially reduce the area of the streambed and streambanks exfiltrating surface water to 24 groundwater. 25 According to my analysis, operation of new proposed intakes along the Sacramento 26 River as proposed by the Delta Tunnels project (see SJC-224; see also LAND-3 and LAND- 27 28 ______6 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 120) would reduce the quantity of surface water recharge to each of the two Subbasins based 2 upon their current and historic condition of receiving groundwater recharge from the 3 Sacramento River below the diversions and the Mokelumne River below the DCC. Reducing 4 the amount of groundwater recharge would deplete the groundwater storage in the South 5 American Groundwater Subbasin and the Eastern San Joaquin Groundwater Subbasin. 6 My analysis indicates the depletion of the groundwater stored in these Subbasins by the 7 proposed diversions would be substantial on an annual basis in terms of acre-feet per year 8 removed from each Subbasin’s water budget. It also indicates the depletions will be substantial 9 in terms of the acre-feet of water stored in the groundwater aquifer beneath each Subbasin 10 over both the 20-year implementation horizon and a 50-year planning horizon described the 11 SGMA. The reduction in groundwater storage for the South American Groundwater Subbasin 12 over a 20-year period is estimated to be approximately 14,500 acre-feet of water, and over a 13 50-year period is estimated to be approximately 36,300 acre-feet of water. The reduction in 14 groundwater storage for the Eastern San Joaquin Groundwater Subbasin over a 20-year 15 period is estimated to be at least 6,000 acre-feet of water and over a 50-year period is 16 estimated to be approximately 15,000 acre-feet of water. Similarly, over the life of the Delta 17 Tunnels project, both from the Early Long Term (year 2025) out to the Late Long Term (year 18 2060) timeframes, the reduction in groundwater storage for the Subbasins as a direct result of 19 new diversions for the Delta Tunnels off the Sacramento River would be substantial. 20 B. Approach to Analysis 21 My analysis was based upon data and information provided by the US Geological 22 Survey (USGS), the DWR, the East Bay Municipal Utilities District (EBMUD) and the 23 Woodbridge Irrigation District (WID). In addition, my analysis has considered information 24 provided by the proponents of the water rights change petition, including information found (or 25 not found) in DWR-4 Errata, DWR-5 Errata, DWR-61, DWR-66, DWR-411, DWR-500, and 26 27 28 ______7 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 DWR-515. For purposes of my analysis of modeling data prepared by DWR for this petition, I 2 focused on Operational Scenario H3 for Alternative 4A. 3 My analysis is premised upon historical data and historic estimates by others of river 4 flows and diversions in these Subbasins. I have used these data to evaluate conditions that 5 would result with and without operation of the proposed new points of diversion. The 6 quantification I have performed, while based upon and governed by careful analysis of the 7 physics of water movement, and the return frequency of surface water flow conditions due both 8 to project operations and to climatic variables, is an informed estimate. It should not be 9 considered precise as to the absolute numbers. However, my method takes account of the 10 changing physical interface over which surface water to groundwater exchange occurs via the 11 change in wetted perimeter and surface area whereas most other methods of quantification 12 such as numerical models of this water exchange do not take account of the change in wetted 13 perimeter. 14 Both the South American and Eastern San Joaquin Groundwater Subbasins, as defined 15 by DWR and updated in 2016, are perennially recharged by the rivers along their boundaries. 16 The proposed new diversions would reduce the elevations of surface water (river stages) in the 17 downstream reaches of the Sacramento River and Mokelumne River. (See DWR-5 errata, 18 slides 75-82 [discussing water level stage changes]; see also DWR-66, pp. 9-10.) This chronic 19 change in river stage would reduce the surface area over which these impacted river reaches 20 would exfiltrate surface water to recharge groundwater. 21 I have developed detailed estimates of the change in river stage by project operating 22 period and by month for each of the Subbasins as described in the following subbasin-specific 23 sections using a return frequency analysis of surface water flow conditions from 1951 to 2017. 24 It is noted that while there would also be a very small change in the pressure head of 25 the water along some of the wetted perimeter for each impacted reach due to the small change 26 27 28 ______8 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 in river stage, I considered this to be insignificant in my assessment of the magnitude of the 2 effects on each of the Subbasins. 3

4

5 Changes in Recharge to South American Groundwater Subbasin 6 The South American Subbasin is bounded by the Sacramento River on its west side. 7 The South American Groundwater Subbasin has groundwater elevations below the elevation 8 of the surface water in the Sacramento River. The hydraulic head (a.k.a. groundwater 9 elevations) in the shallow groundwater aquifer in the South American Groundwater Subbasin 10 drops below sea level just south of the City of Sacramento. 11 As mentioned previously Exhibit SJC-225 contains DWR’s depiction and interpretation 12 of hydraulic heads for Spring 2015. As can be seen in the figure, the data and DWR’s 13 contouring of it depict that zero feet of hydraulic head in relation to mean sea level exists along 14 the Sacramento River above the proposed intakes. These contours and data signify that all 15 Sacramento River reaches below that point are discharging surface water to the groundwater 16 of the South American Subbasin. Further Exhibit SJC-225 also displays DWR’s contours of the 17 Spring 2015 groundwater elevations in the subbasin, but is overlain by DWR with color 18 ramping; this second depiction of the same dataset further illustrates which areas of the 19 subbasin have groundwater elevations below mean sea level. These conditions of 20 groundwater elevations below sea level and Sacramento River surface water stage height 21 have existed for many years, and thus the Sacramento River recharges the groundwater 22 subbasin, essentially from the City of Sacramento southward all along the western boundary of 23 the subbasin. (See also SCWA-40 for a depiction of groundwater conditions in the South 24 American Groundwater Subbasin.) 25 Exhibit SJC-228 depicts both the reach of the Sacramento River below the proposed 26 intakes, and a line of section across the South American Groundwater Subbasin used in 27 28 ______9 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 Exhibit SJC-229. The reach of the Sacramento River along the boundary of the South 2 American Groundwater Subbasin that would be depleted of surface water by the proposed 3 new diversions is at least 11.9 river miles long from the southerly intake, Intake No. 5 to the 4 DCC. My evaluation could have been expanded to include the depleted reach from Intake No. 5 2 to Intake No. 3, and then the reach from Intake No. 3 to Intake No. 5. The magnitude of the 6 depletion of groundwater storage would increase if these additional two reaches were included 7 in my analysis. This is not insignificant as the two reaches total 4.3 river miles altogether; 8 however, the change in river stage among the intakes is more awkward to estimate with 9 precision but it can be done and the added reduction of groundwater recharge to the South 10 American Groundwater Subbasin quantified. 11 Exhibit SJC-229 depicts groundwater elevations in a cross-section view relative to the 12 Sacramento River stage. The data depicted on the first page of Exhibit SJC-229 for Spring 13 2015 are taken from USGS’ NWIS system and DWR’s Water Data Library. Exhibit SJC-229 14 also identifies the groundwater well locations and groundwater elevation databases maintained 15 by the US Geological Survey (USGS) and the DWR. Exhibit SJC-230 depicts the 16 corresponding Sacramento River stage data from Spring 2015 approximated from the USGS 17 Freeport Gage (USGS Station ID 11447650) within the period of October 1, 2010 to November 18 14, 2017 depicted. 19 These data demonstrate that, with the river stage above the adjoining groundwater 20 hydraulic head in the Subbasin, the Sacramento River recharges the South American 21 Groundwater Subbasin. This condition of groundwater recharge of the Subbasin from the 22 Sacramento River in the reach below the proposed new intakes has likely existed for more 23 than 30 years, as demonstrated by the time history of groundwater elevations depicted in 24 Exhibit SJC-231 for State Well No. 07N06E12A001M. The groundwater elevation (hydraulic 25 head) in State Well No. 07N06E12A001M which is in the middle of the Subbasin first dropped 26 below sea level in 1977. The hydraulic head in this well in Fall 2014 was -29.4 msl (i.e., 27 28 ______10 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 approximately 29 feet below sea level) and in Spring 2015 was -22.9 msl (i.e., approximately 2 23 feet below sea level); thus the hydraulic head as of January 1, 2015 in relation to the 3 enactment of SGMA sustainability metrics could reasonably be expected to lie somewhere 4 between these two endpoint measurements. SJC-231 is a representative indicator of the long- 5 term and chronic condition of groundwater recharge to the South American Groundwater 6 Subbasin from the Sacramento River. 7 To estimate the reduction in groundwater recharge to the South American Groundwater 8 Subbasin, I evaluated the modeled project diversions into the proposed intakes under 9 Petitioners’ Alternative 4A H3 Scenario as provided to me for the period of March 1951 to 10 September 2003. (DWR-500, Alternative 4A Scenario H3) This period of simulation is of 11 interest because it coincides with the actual CVP diversions in March 1951 up to the date that 12 the proponents stopped their hypothetical water diversion simulations using CalSim. 13 I also utilized data and information produced by DWR in Exhibits SJC-232, SJC-233 14 and SJC-234 as well as monthly Sacramento River flow data from the USGS Freeport Gage in 15 Exhibits SJC-235, and SJC-236 for my analysis of surface water and groundwater interaction. 16 Exhibits SJC-232, SJC-233 and SJC-234 provide the sources of the data and information from 17 DWR on stream rating curves for the Sacramento River at the Freeport Gage; I used these 18 rating curves from a calibrated integrated hydrologic model, C2VSim, to develop estimates of 19 the change in wetted perimeter due to the relative increase or decrease in Sacramento River 20 stage. The river stage changes and wetted perimeter changes are a function of both the 21 baseflow rates by month in the Sacramento River and the diversion rates by month. I also 22 evaluated the USGS’s rated monthly outflow of surface water at the USGS Freeport Gage 23 (USGS Site Number 11447650 over the same period, March 1951 to September 2003. I 24 developed graphs of streamflow data and proposed project diversions by month and grouped 25 these by DCC Operations Period provided in SJC-237. 26 27 28 ______11 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 I developed a return-frequency analysis comparing the different baseflow conditions in 2 the Sacramento River to a return frequency analysis of Petitioners’ proposed diversions using 3 those actual flow conditions from the temporal synchronization of USGS measured flow rates 4 and DWR’s CalSim modeled new diversions for these same climatic type periods. I used this 5 correlation of actual temporal baseflow data to Petitioners’ model-derived diversion estimates 6 for the proposed project. 7 As a side note, I cataloged the actual CVP and SWP diversions and rates provided by 8 DWR in SJC-234 from July 1967, when both the CVP and SWP diversions are present to 9 quickly compare those to the analogous CalSim-projected diversions. The overall average 10 monthly flow rate for the actual diversions from the Delta in the period July 1967 to September 11 2003 is 3,081 cubic feet per second (cfs). The overall average monthly diversion flow rate from 12 all Delta pumping plants depicted in the Alternative 4A Scenario H3 is 7,356 cfs, and of that 13 total diversion rate, an average monthly flow rate of 4,149 cfs would be diverted at the new 14 proposed intakes. This quick comparison of flow-weighted averages makes it easy to see that 15 for the same types of Water Years as the Sacramento River and watershed experienced 16 historically, Petitioners intend to divert more water than has been done historically for the CVP 17 and SWP. I did not take this comparative analysis further but I felt it was worth noting as a 18 general matter in regard to both past use of water resources of the State of California and 19 proposed future use. 20 For my detailed analysis of the CWF Project effects on groundwater recharge, I used a 21 return-frequency analysis by month of the year of actual monthly flow estimates from data 22 made by the USGS and a return-frequency analysis by month of the 52 water years mentioned 23 above, March 1951 through September 2003. This enabled a temporal analysis of likely project 24 impacts on groundwater recharge by month of the year (e.g., January and not January of any 25 particular year). The return-frequency intervals I utilized are: 95% Exceedance, 90% 26 Exceedance, 80% Exceedance, 70% Exceedance, 60% Exceedance, 50% Exceedance, 40% 27 28 ______12 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 Exceedance, 30% Exceedance, 20% Exceedance, 10% Exceedance, and 5% Exceedance, for 2 historic flow rate frequencies by month of the year and for the frequency of historic flow rates 3 minus proposed representative diversion rates. Each was evaluated separately as to the 4 resulting flows below the proposed Delta Tunnel Project intakes near Hood, California. 5 By evaluating the temporal return frequency of the historic actual measured flow 6 conditions at the Freeport Gage, as opposed to using a model estimate and also evaluating 7 the contemporaneous time history of proposed diversion rates Petitioners have asserted they 8 would use in such Water Years, I was able to evaluate the time-weighted averaging of the 9 effect on Sacramento River flows adjoining the South American Subbasin below the proposed 10 new intakes. If the proposed new diversions are built and operated above this reach it would 11 lower the river stage in accordance with the rating curve and this will lower the wetted 12 perimeter. Note that historic conditions do not remove surface water flows above this reach 13 and the Freeport Gage within it. Also, the historic measured flows at the Freeport Gage 14 included releases from upstream reservoirs for diversion to the CVP and SWP, as well as for a 15 variety of other needs for water resources in the Delta, such as habitat support for salmonids 16 and other fish, as well as for net Delta outflow (NDO) to prevent brackish water from intruding 17 further into the Delta. 18 The resulting datasets used in my analysis are the monthly historic rated flows by the 19 USGS, and the resulting monthly historic flows net of the proposed diversions under the 20 Alternative 4A H3 Scenario. These resulting datasets are provided in Exhibit SJC-250. In my 21 opinion, these datasets provide a reasonable starting point for any analysis of prospective 22 impacts from the proposed new diversions. The actual historic Sacramento River flows in 23 these same Water Years and Water Year types are the best information available for 24 evaluating and forecasting future project effects on Sacramento River flow and stage from a 25 non-parametric decision-support model such as CalSim. The CalSim monthly hypothetical 26 diversion flow rates for the proposed new intakes, when taken over a lengthy period of time 27 28 ______13 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 and then simultaneously compared to actual river flow rates, provide a reasonable basis for 2 evaluating how the proposed project would operate according to DWR under Alternative 4A 3 Scenario H3, and how those operations would impact river flow rates in general for any month 4 of the year. It is essentially a statistical approach for looking at climatic conditions and 5 proposed project operations and evaluating how often the project will impact groundwater 6 recharge and by how much. 7 For my analysis, I placed the monthly river and project diversion flows into temporal 8 “bins”. These temporal bins are the annual periods that correspond to the different periods for 9 the DCC operations. This was done to enable subsequent evaluation of the change in flow 10 conditions for the Mokelumne River that result from the use of the DCC during its operational 11 rule periods, and to maintain a consistency of presentation to aid those reviewing my analysis 12 of likely impacts to each of the Subbasins. The South American Groundwater Subbasin 13 analysis is the one described here. 14 The four annual DCC operations periods are described in Exhibit SJC-238 (Delta Cross 15 Channel Operations presented by the Bureau of Reclamation circa 2006) (see also SWRCB- 16 84, 2009 NMFS BO, pp. 631-640). For my analysis I have named those DCC operations 17 periods, Early Year Runoff (February 1 to May 20), Late Spring (May 21 to June 15), Dry 18 Season (June 16 to October 31), and Winter (November 1 to January 31). One should note 19 that the DCC operations have no influence on my estimates for the impacts to the Sacramento 20 River reach adjoining the South American Groundwater Subbasin since the DCC inlet gates 21 are downstream of this reach, which is depicted in Exhibits SJC-224 and SJC-228. Again, the 22 organization into these time-period bins was done for clarity of presentation of the two 23 Subbasins. 24 The return frequency interval for the change in river flow and resulting change in the 25 wetted perimeter of the river from the proposed change in the location of the points of diversion 26 were evaluated for each month of the year. I selected the 11 return frequency flow exceedance 27 28 ______14 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 intervals listed previously (95% Exceedance, 90% Exceedance, 80% Exceedance, 70% 2 Exceedance, 60% Exceedance, 50% Exceedance, 40% Exceedance, 30% Exceedance, 20% 3 Exceedance, 10% Exceedance, and 5% Exceedance) to provide a high degree of precision to 4 estimates of the chronic effects of the proposed new project diversions over a wide variety of 5 Water Year Types as rated by the DWR for the Sacramento Valley. (Exhibit SJC-239) 6 Use of a return frequency intervals analysis provides a reliable method of predicting chronic 7 impacts by month. This is somewhat analogous to evaluating the climate of a region for the 8 month of January versus the weather of a region for any particular January in a given year. 9 However, given the high variability in even monthly average river flows, it is essential to look at 10 how often a river flow exceeds a certain flow rate; hence the use of 11 percentile ranges with 11 their appropriate frequency interval splits (e.g., 95% Exceedance is used to represent 5% of 12 the flow conditions, 95%-100% Exceedance flow conditions) 13 The reduction of the quantity and rate of groundwater recharge that would result from 14 the new proposed diversions on the South American Groundwater Subbasin would be chronic 15 and perpetual. Groundwater elevations adjacent the Sacramento River downstream of the 16 proposed diversion are below sea level and below the Sacramento River stage. (See, e.g., 17 USGS Station Code 381617121315501 for State Well Number 005N004E22F001M in 18 Courtland, California in Exhibit SJC-229.) 19 This hydraulic gradient outward from the Sacramento River to the adjoining Subbasin 20 indicates that the Sacramento River is recharging the Subbasin. This river discharge to 21 groundwater recharge occurs at all times. It changes magnitude due in part to tidal impacts on 22 river stage but those can reasonably be predicted. The variability in river discharge to 23 groundwater recharge occurs as a function of the temporal averages in Sacramento River flow 24 rates, new proposed diversions and their diversion rates, and the resulting wetted perimeter of 25 the Sacramento River around its bed and banks. 26 27 28 ______15 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 Using a time-weighted-averaging approach from frequency analysis of historic flows and 2 their corresponding new diversions rates generated by CalSim (from Exhibit DWR-500) 3 provides a reasonable and reliable estimate of the chronic change in groundwater recharge by 4 month of the year that would occur due to operation of the proposed CWF Project intakes as a 5 new point of diversion for the water rights. The annual reduction in groundwater recharge to 6 the South American Groundwater Subbasin is estimated be 726.4 acre-feet per year (AFY), or 7 roughly 700 AFY. Exhibit SJC-240 presents the inputs and outcomes of my analysis of impacts 8 from the proposed removal of water from the Sacramento River on the South American 9 Groundwater Subbasin. 10 Because this analysis uses a time-weighted average of the frequency of a wide variety 11 of flow conditions, coupled to the corresponding proposed new diversions over a more than 12 52-year period, it is appropriate to treat this loss of 700 AFY as the chronic groundwater 13 depletion rate of the South American Groundwater Subbasin. The same could not be said of a 14 flow-weighted averaging method of analysis. Projecting these impacts into the future, if the 15 proposed project operated over a 20-year planning horizon, then a reduction of 14,000 acre- 16 feet of groundwater storage would need to be accounted for in sustainable groundwater 17 management of this adjoining South American Groundwater Subbasin. Similarly, if the 18 proposed project operated over a 50-year planning horizon, then a depletion of 35,000 acre- 19 feet of groundwater storage would need to be accounted for in sustainable groundwater 20 management of this adjoining South American Groundwater Subbasin. The proposed new 21 diversions would equate to a new groundwater extraction such as a linear horizontal drain with 22 a perpetual removal rate of 450 gallons per minute pumping alongside the river and within the 23 Subbasin. 24 Changes in Recharge to Eastern San Joaquin Groundwater Subbasin 25 The limits of the Eastern San Joaquin Groundwater Subbasin are defined by the north 26 fork of the Mokelumne River along its northwestern boundary, SJC-224. (Also see LAND-124, 27 28 ______16 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 CASGEM Basin Prioritization - North Central Region.) The Eastern San Joaquin Groundwater 2 Subbasin has groundwater elevations below the elevation of the surface water in the 3 Mokelumne River. The hydraulic head (a.k.a. groundwater elevations) in the shallow 4 groundwater aquifer in the Eastern San Joaquin Groundwater Subbasin drops below sea level 5 just west of the Town of Clements and remains below sea level all the way west to its 6 northwestern boundary. Exhibit SJC-226 contains DWR’s depiction and interpretation of 7 hydraulic heads for Spring 2015 that demonstrates this condition. The data, and DWR’s 8 contouring of it, depicts that zero feet of hydraulic head in relation to mean sea level exists 9 along the Mokelumne River above the proposed new diversion locations and the DCC. 10 These groundwater elevation contours show that the Mokelumne River and its 11 distributary branches within the Delta are discharging surface water to the groundwater of the 12 Eastern San Joaquin Subbasin. The data indicate that groundwater recharge is most likely 13 occurring now and as importantly was occurring in the area downstream of where the DCC 14 adds flow to the Mokelumne River from the Sacramento River on and prior to January 1, 2015. 15 Exhibit SJC-226 also displays DWR’s contours of the Spring 2015 groundwater 16 elevations in the subbasin overlaid by DWR’s color ramping. This second depiction of the 17 same dataset further illustrates which areas of the subbasin have groundwater elevations 18 below mean sea level. The areas of the subbasin near its northwestern boundary are 19 recharged by the Mokelumne River and its within the Delta. This condition of 20 groundwater elevations in the subbasin being below sea level and correspondingly below the 21 surface water stage in the Mokelumne River have existed for many years. (See also Exhibit 22 SJC-241, the current Groundwater Management Plan for the Eastern San Joaquin 23 Groundwater Subbasin) In or around 1980, the Eastern San Joaquin Groundwater Subbasin 24 was determined to be in a state of critical overdraft by the DWR. The Mokelumne River has 25 recharged the groundwater subbasin along its northwestern boundary for at least four 26 decades. 27 28 ______17 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 Exhibit SJC-242 depicts the reaches of the Mokelumne River that are below both the 2 proposed Delta Tunnel’s project intakes and the DCC as well as the distributaries of the 3 Mokelumne within the Delta above its with the , namely Little 4 Potato Slough, Potato Slough, and Little Connection Slough. As explained below, these 5 distributary channels would also be impacted by the change in stage induced by the proposed 6 project. Exhibit SJC-242 also depicts a section line across the Eastern San Joaquin 7 Groundwater Subbasin used in Exhibit SJC-243 to demonstrate groundwater elevations 8 relative to the Mokelumne River stage, mean sea level, and land surface across the Subbasin. 9 These reaches of the Mokelumne River along the northwestern boundary of the Eastern San 10 Joaquin Groundwater Subbasin would be depleted of riverine flow and correspondingly river 11 stage height and the wetted perimeter in flow. These river reaches that would be impacted by 12 the proposed diversion relocation for the CVP and SWP to the project intakes, total 13 approximately 39.8 river miles in length. 14 Exhibit SJC-243 depicts the groundwater elevations in the cross-section view relative to 15 the Mokelumne River stage from Spring 2015 found within the same Exhibit that were taken 16 from DWR’s Water Data Library ( www.water.ca.gov/waterdatalibrary/) Exhibit SJC-243 17 demonstrates that the Mokelumne River and its distributaries in the Delta were providing 18 recharge to groundwater in the Eastern San Joaquin Groundwater Subbasin in the Spring 19 2015, and almost certainly on January 1, 2015 as well as prior to 2015. 20 As described previously for the South American Groundwater Subbasin, I evaluated the 21 Eastern San Joaquin Subbasin by evaluating the proposed CWF Project diversions from 22 March 1951 thru September 2003. (Exhibits SJC-232, SJC-233, SJC-234, and SJC-250.) I 23 evaluated the USGS’s rated monthly outflow of surface water in Exhibits SJC-235 and SJC- 24 236 over the same period to assess with what frequency and flow volume of water from the 25 Sacramento River can be forecast to be conveyed via the DCC to the Mokelumne River. This 26 was done by analyzing the operations data from 1985 thru 2003 provided in Exhibit SJC-238. I 27 28 ______18 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 have summarized those DCC operations data by the aforementioned operating periods (e.g., 2 Early Year Runoff Period) in graphical and tabular form in Exhibit SJC-244. For this analysis, I 3 utilized the same return-frequency intervals to analyze historic Sacramento River flows above 4 the DCC. 5 By evaluating the temporal return frequency of measured ambient flow conditions and 6 the same temporal flow conditions minus the project diversions I am able to evaluate the time 7 weighted averaging of the effects on river flows above the DCC. Using these time periods 8 “bins” corresponding to the operating periods DCC enabled evaluation of the change in flow 9 conditions for the Mokelumne River that result from the use of the DCC during its operational 10 rule periods. It is these resulting operations that impact groundwater recharge to the Eastern 11 San Joaquin Subbasin. 12 The operations of the DCC do have an effect upon the Eastern San Joaquin Subbasin 13 by historically increasing the flow rate and river stage in the north fork of the Mokelumne River 14 (i.e., the main stem of the river) and its distributary channels within the Delta, the south fork of 15 the Mokelumne, Little Potato Slough, Potato Slough, and Little Connection Slough above their 16 confluence with the main stem San Joaquin River. The proposed reduction in flow of the 17 Sacramento River above the DCC under operation of the project would result in the 18 downstream reduction in river stage and the wetted perimeter in each of these reaches of the 19 Mokelumne River without any change in DCC operating rules. 20 My calculations find that flow conditions in the Sacramento River would trigger opening 21 less frequently or more frequently depending on the DCC operating period based upon the 22 return frequency of Sacramento River flows net of the proposed project diversions, primarily 23 criteria for flows in excess of 25,000 cfs and criteria for flows remaining above 5,000 cfs in the 24 Sacramento River. These temporally weighted estimates of the change in DCC operations are 25 not the result of any projected change in DCC Operations to satisfy the Biological Opinions or 26 to satisfy structural safety requirements for the DCC and its headgates. They are a function of 27 28 ______19 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 the change in rated flow and stage height in the Sacramento River net of the proposed 2 diversions above the DCC. 3 To evaluate the changes in flow in the Mokelumne River from historic diversions 4 through the DCC to the SWP and CVP intakes in the South Delta, I utilized the rating curve for 5 the Mokelumne River at found in Exhibit SJC-234 and I gathered data on 6 Mokelumne River flows. Exhibits SJC-245, SJC-246 and SJC-247 provide monthly data over 7 the period from 1928 to 2016 on flows and diversions within the Mokelumne River from the 8 USGS, Woodbridge Irrigation District (WID), and the East Bay Municipal Utility District 9 (EBMUD). There are a number of confounding factors that limit the precision of these monthly 10 return-frequency interval flow analyses, most significantly the flow control placed upon the 11 ambient river flows in the Mokelumne River by the EBMUD’s . However, the 12 diversions by both WID and EBMUD are taken outside (upgradient) of the area of impact from 13 the proposed project effects. Furthermore the flows into Camanche Dam and out of it, have to 14 net out to zero by definition, discounting for the initial dam fill volumes for both EBMUD Dams 15 on the Mokelumne, the Camanche Dam and the . 16 The return-frequency intervals for monthly Mokelumne River flows located at the USGS 17 Mokelumne Hill Gage (USGS Station 11319500) are within the operating norms for river 18 releases on the river. The maximum monthly river inflow over the period 1928 to 2016 was 19 6,243 cfs. The median value of river inflow was 804 cfs and the modal, most frequently 20 occurring rate, was 483 cfs. (See Exhibit SJC-245). I incorporated the modern diversions of 21 water off of the Mokelumne River above the DCC to the temporal frequency of upper 22 watershed inflows to develop a return frequency analysis of available water and thereby 23 ratable flows. Exhibit SJC-254 provides a tabulation of this analysis that is used subsequently 24 to calculate the change in Mokelumne River exchange with groundwater below the DCC. 25 When open, the DCC can reportedly direct up to 3,500 cfs of Sacramento River flow 26 into the Mokelumne River and its distributary channels. (Exhibit SJC-238) 27 28 ______20 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 I evaluated the change in Mokelumne River flow and the resulting change in wetted 2 perimeter from the proposed change in the location of the points of diversion for each month 3 and fraction thereof during each DCC Operating Period. My analysis of the return frequency of 4 DCC operation and the diverted flow rate thru the DCC is based upon the Bureau of 5 Reclamations statements in regard to DCC Operations found in Exhibit SJC-238. This 6 controlled the rule curve I utilized for my analysis of DCC diverted flows. 7 The rule curve for the use of DCC diversions is summarized as follows. If net flows in 8 the Sacramento River at the DCC with and without the project are projected above 25,000 cfs 9 for any return frequency interval, then the DCC diverts no water. If net flows in the Sacramento 10 River at the DCC with and without the project are below 25,000 cfs and above 8,500 cfs for 11 any return frequency interval, then the DCC diverts up to 3,500 cfs to meet the Delta 12 diversions DWR provided for Alternative 4A Scenario H3, or the required Delta diversion, 13 whichever is smaller. 14 However, to evaluate the chronic effects on groundwater recharge these flow rates in 15 any given month are reduced by a temporal weighting for each of the four annual operations 16 periods based on historic operations data provided by the Bureau of Reclamation in Exhibit 17 SJC- 238 and depicted in Exhibit SJC-244. For example, if the average percentage of 18 operation in the Early Year Runoff Period of February thru May 20 has historically resulted in 19 the DCC being open 76.7% of the time, then this temporal weight was applied to say a peak 20 flow rate of 3,500 cfs to a temporally weighted average for each return frequency interval. 21 If net flows in the Sacramento River at the DCC with and without the project are less 22 than 8,500 but greater than 5,000 cfs then the DCC would divert half the flow rate projected by 23 the CalSim forecast of Alternative 4A Scenario H3 put forth by the project proponents. This 24 estimated flow rate for a specific return frequency interval in a given month such as February is 25 again reduced by the historic operations temporal frequency weightings for this DCC 26 operations period, the Early Year Runoff in this instance. 27 28 ______21 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 Lastly, if the projected Sacramento River net flow rate is below 5,000 cfs for any return 2 frequency interval then the DCC is not open in the analysis. I will note here that actual 3 operations of the DCC have not adhered to this upper flow rate operational rule flow rate of 4 25,000 cfs; for example in Early Year Runoff Period 1995 the DCC was open 100% of the time 5 while average Sacramento River flows at the Freeport Gage (just upstream of the DCC) were 6 on the order of 50,000 cfs. By adhering to this rule curve and using actual operations data 7 provided, I have provided the most accurate estimates possible based on the information 8 provided by those operating the DCC. 9 The return frequency intervals for flows via DCC diversions were then added to the 10 return frequency intervals for flows in the Mokelumne River. These resulting flow rates by 11 month were then evaluated for change in river stage using the DWR’s rating curve for the 12 Mokelumne River found in Exhibit SJC-234. This approach enabled calculation of the change 13 in wetted perimeter for the Mokelumne River and its distributaries overlying and adjoining the 14 Eastern San Joaquin Groundwater Subbasin. 15 I considered Exhibit SJC-249 in my analysis as well. Exhibit SJC-249 describes the 16 characteristics of Mokelumne River sedimentary deposits over time and their high permeability 17 as well as their continuity with depth. This means that the Mokelumne River has a high net rate 18 of groundwater recharge with changes in wetted perimeter. 19 The overall effect from the proposed project diversions on groundwater recharge to the 20 Eastern San Joaquin Groundwater Subbasin would be chronic. However, they likely would not 21 occur every year depending upon operating conditions for the DCC. There are times of year 22 when flow conditions in the Sacramento River without the proposed project (i.e., under current 23 and historic operation of the SWP and CVP) would provide no change in the ambient 24 groundwater recharge of Mokelumne River water to the Subbasin. However, since the 25 groundwater elevations in the subbasin are below the Sacramento River stage at all times and 26 the diversions would be chronic, the reduction in the quantity of groundwater recharge can 27 28 ______22 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 properly be quantified as a chronic reduction in groundwater recharge using time-weighted 2 frequency analysis. The variability is only with regard to the magnitude of the impact. Using a 3 time-weighted-averaging approach that matches historic flows with their corresponding 4 diversions, results in an estimate of the change in groundwater recharge with the project 5 removing Sacramento River flow and river stage above the DCC, and the corresponding 6 changes in Mokelumne River flow and river stage. My detailed analysis indicates that the likely 7 reduction in annual groundwater recharge to the Eastern San Joaquin Groundwater Subbasin 8 from the proposed new diversions would be at least 300 AFY. Exhibit SJC-248 provides the 9 inputs and outcomes of my analysis of this estimated reduction in groundwater recharge to the 10 Subbasin. 11 Because this is a time weighted average over a 52-year period of analysis correlative 12 with Sacramento River flows and Mokelumne River flows and diversions, it is appropriate to 13 treat it as the chronic condition (as compared to some type of flow weighted averaging). 14 Projecting these impacts into the future, if the project were to operate over a 20-year planning 15 horizon then a reduction of more than 6,000 acre-feet of groundwater storage would need to 16 be accounted for in sustainable groundwater management of this adjoining Eastern San 17 Joaquin Groundwater Subbasin. Similarly, if the Delta Tunnels project operated over a 50-year 18 planning horizon, then a reduction of more than 15,000 acre-feet of groundwater storage would 19 need to be accounted for in sustainable groundwater management of this adjoining Eastern 20 San Joaquin Groundwater Subbasin. This proposed new diversions would equate to a new 21 groundwater extraction, one with a perpetual removal rate of approximately 185 gallons per 22 minute like that of a horizontal drain. 23 This is concerning given that the Eastern San Joaquin Groundwater Subbasin has been 24 assessed by DWR to be in a continued state of critical overdraft. 25 Additional Observation in Regard to Proposed and Project Operation of the CVP and 26 SWP with the Delta Tunnels Project 27 28 ______23 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 I made another pertinent observation in performing my analysis of the effects proposed 2 new diversions. The observation came from analyzing DWR’s CalSim monthly operational run 3 information for the proposed North Delta Diversions and the existing South Delta Diversions. 4 While evaluating the historic flows in both the San Joaquin River and the Sacramento River 5 (see SJC-250), I endeavored to establish how much water would or could be diverted via the 6 DCC and how much water would be available from the San Joaquin River inflow to the Delta 7 over the same historic period of Water Year 1951 through Water Year 2003. 8 What I found is that there are frequent monthly intervals in which the project proponents 9 appear to have not accounted for enough water to satisfy the current South Delta diversions. I 10 flagged these intervals as “Insufficient Water” in SJC-250 using an algorithm to check the 11 overall water availability. Surprisingly, they occur most frequently in December. (see Page 12 12 in SJC-250) More importantly, they represent insufficient water being supplied in this 13 hypothetical scenario of these Water Year Types and diversions as well as Delta Outflows; the 14 result of such conditions is to demand water out of the Delta pool itself. This overdrafting of 15 active flows into the Delta would by definition cause increased San Joaquin River flow 16 reversals and brackish water intrusion into the estuary. The CalSim model based forecasts 17 made by DWR in DWR-500 over historic Water Years for Alternative 4A Scenario H3 require 18 significant scrutiny as to their validity and the types of flow conditions that could be reasonably 19 anticipated in and around the Sacramento-San Joaquin Delta. 20 III. CONCLUSION 21 In my opinion, the removal of the volume of groundwater recharge from these two 22 Subbasins, and the corresponding reduction of their annual and long-term groundwater 23 budgets, would be detrimental. The two Subbasins adjoin river reaches that would be impacted 24 if the new diversions proposed by the Delta Tunnels project go forward. The reduction in 25 groundwater recharge would also make it more difficult for the relevant Groundwater 26 Sustainability Agencies and other groundwater users to reach sustainability, as required by the 27 28 ______24 WRITTEN TESTIMONY OF JOHN LAMBIE (PART 2 CASE IN CHIEF)

SJC-223 1 SGMA. Allowing the water rights actions contemplated for the Delta Tunnels project to further 2 strain these already stressed groundwater Subbasins would not be in the public interest for 3 management of the State of California’s water resources. 4

5 Executed at Portland, Oregon, on November 30, 2017.

6

7 8 JOHN M. LAMBIE 9

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