Flood Control and Water Conservation District - Regular Meeting

Welcome everyone to the 04/09/2026 meeting of the Technical Advisory Group, better known as the TAG. The committee invites comments and recommendations from the public concerning issues relevant to the charge of the technical advisory group. Anyone who wishes to speak to the TAG on such a matter, if it is not on the agenda, may do so at this time. At the discretion of the chair, individuals will be limited to a three minute presentation. No action will be taken by the TAG as a result of any item presented at this time.

Members of the public who wish to make public comment on a matter not on the agenda, but are within the subject matter jurisdiction of the commission will have three minutes per speaker and may do so now. Please proceed to the podium. Anyone online or?

We have no callers.

Okay. Okay, our next order of business is the clerk of committee requests approval of minutes from the regular meeting held on 03/12/2026.

I think we need to do our roll call first.

Oh, okay. Call to order. I did skip over

that part.

That's okay.

Apologies.

Member Phillippelli?

Here.

Member Cooper? Present. Member Chambaughan?

Here.

Member Garcia?

Present.

Chair Kondoff?

Here.

Thank you.

Okay. Now if I can request approval of minutes from the regular meeting of March 2026.

Motion to approve.

Second.

All in favor of approving the minutes?

Aye.

Aye. Okay.

The motion is approved. Minutes are adopted. So any member of the tag with any news or or item to report? Bring up. Staff?

We do not have any reports or announcements at this time, but I think we did have, a member of the public who is either called in or Zoomed who has a public comment.

Okay.

Hand just went up. It's hard to keep track

of them all.

Okay.

Don, you will have three minutes.

Don, can you hear us? Do you?

Can you hear me now? Yep.

Now we can hear you.

Yeah. No comment other than there is no video coming through, at least to my laptop. I don't know if there's others online that can verify they're not seeing what's going on.

Thank you, Don. We're working on that.

Alright.

For future agenda items, are there any comments or reports from members of the TAG? Okay. So no, actually I was jumping ahead there. Okay, so administrative items.

Yep, and the first one of those is the annual report presentation for water year 2025. We're going have a presentation from Vicki Kressinger Graebert from Blue Dorks Galminini Consulting Engineers.

And IT is working on getting that set up, so maybe we could take a breather for twenty seconds until they get everything in order.

We'll begin with presentation of the Water Year two twenty five Annual Report. And I'll turn it over to Vicki.

Thank you. And good afternoon, tag members after first recess and early recess. So I'm here, Vicky Kretzinger Gruybert from Lidorf and Skalmanian Consulting Engineers to present highlights of the Napa County Groundwater Sustainability Annual Report Water Year twenty twenty five on behalf of, a number of folks prepared for the Napa County Groundwater Sustainability Agency. So this was prepared by LSCE along with ERA economics and Stillwater Sciences and Napa County RCD and Napa County. So it's a a large report, covers a lot of information.

This is the eleventh report, for the county and the fifth report, for annual reporting as required by the Groundwater Sustainability Plan regulations. So I'm gonna hit highlights on twenty twenty five conditions, some key aspects of the sub basin water budget, information on sustainable management criteria for the sustainability indicators, and then some key things that have occurred for groundwater sustainability plan implementation. The tag has seen this graphic before,

which

shows historical precipitation at the Napa State Hospital. And this is just used as an illustration because of its long record. And we see changes in water year types over time. And then coming to more current water years, we have below average normal conditions, but below average in the water year 2025. It's actually even a little bit less than the normal below average year for water year 2024.

The Napa State Hospital is in a relatively drier part of the watershed, and the water year 2025 precipitation was at the state hospital location showed that. And the next slide I'm going to show is what we actually incorporate into the Napa Valley integrated hydrologic model every year when we do an annual update to the hydrologic conditions. And this shows the total annual precipitation over the entire watershed. And you can see from the cooler colors on the northern to central part of the watershed that we had much wetter conditions, higher amounts of precipitation occurring in the North and the West, and decreasing toward the South and the East. And so this is important in the distribution over the watershed because all of the watershed is encompassed by what we do with the integrated hydrologic model, the NVIHM, to estimate water budgets.

This is a graphic showing what's occurred with temperature over time, also at the Napa State Hospital location over a long record from 1950 to 2025. And, the interesting thing about water year 2025 is that there were thirty days above 90 degrees, but that was similar to the historical average, and that amounted to nineteen days, fewer, you know, at that temperature compared to water year 2024. So even though, water year 2025 temperatures aligned with those historical averages, the other thing that we're looking at is hotter, drier conditions and temperatures, generally trending upwards as we look at longer periods of record. So in the next slides, I'm going to go over water budget highlights. This is a summary of total water use data water year 2025, and we're showing the comparison to the two prior water years, just to see things that have changed.

There are not many changes. When we look at the total water use, the bottom line there in bold, we see very comparable, water use numbers for 2025 compared to 2024. When we walk down the different kinds of water uses, groundwater pumping was pretty similar, slightly more in water year 2025. There's a bump up, an increase in native vegetation, what we see from indirect water use from that vegetation, groundwater dependent ecosystems, managed wetlands. Recycled water use is about the same as water year 2024.

We do see some differences when we look at the local surface water use, including reservoirs and surface water diversions. We had a a significant bump up in 2025 compared to 2024. But then when we look down at the state water project water use, we see the opposite. We see less water used from the state water project and compared to water year 2024. When we look at groundwater pumping, more specifically and looking at the different sectors, these are very similar to what we've, discussed in past years where agriculture is, a pretty low amount overall compared to other basins in California.

It's just a little over 12,000 acre feet in the year. It's the majority of the groundwater use. Municipal is 280, acre feet last year, the water year 2025, only 2% of the use. Self supplied users, primarily domestic users on private water supply systems, that's 2,940 acre feet, 18% of the use. So the next compared to agricultural use.

And then small public water systems, little over 1,000 acre feet at 6% of the use. In total, we had 16,580 acre feet for water year 2025. And this is all primarily simulated except for the information that we get from the city of St. Helena for municipal groundwater use. The image on the right hand side, this is output from the NVHM modeling and shows, estimates of the groundwater use on a section basis, those colored squares.

And as you can see, as you look across the sub basin and actually across the active modal area, which includes more than the sub basin itself, it goes down to the bay and also into the MST, the Millikan Sarco Toluca area, which is outside of the sub basin. We see a lot of green to mid mid tone green. So the average range goes from about point three acre feet per acre and then some at the other end of the spectrum, but there are not too many of them in the oranger colored squares that are up to 0.7 acre feet per acre. The next thing that we're looking at in this slide is change in groundwater storage. This is one of the requirements from the Department of Water Resources in the Groundwater Sustainability Plan regulations annually to report the change in storage, and this is based on a required, assessment of what occurs from spring to spring.

So this is from spring twenty twenty four to spring twenty twenty five, and it looks at the change in storage of groundwater in the sub basin during that period. And all of this has influenced over the years. Here we're showing in this graphic the change in storage each year over a historical period from 1988 to present. And the blue bars represent the individual changes from spring to spring. And then the black line with dots, that's showing the cumulative change over time.

For water year 2025, that spring twenty four to spring twenty five, computation, we showed a slight increase in groundwater storage, which was good given that we had a slightly less, precipitation overall in water year 2025. We saw a cumulative storage change, which is holding steady. When you look back at water year 2021, that was when we were at the depth of very dry back to back very dry years, and there was a lot of water taken out of storage at that point in time. And then we had a recovery since that point in time. And since that, it's remained fairly steady.

Next, I'm going to turn to sustainability indicators and the sustainable management criteria that are defined for each of the six sustainability indicators. I'm not going to read everything on this slide, but to hit some highlights, in particular, on the left hand column of this slide, we had the listing of the six sustainability indicators. And the point that I'd like to make is the types of measurements that we're using to track the conditions of that indicator relative to the defined sustainable management criteria. So the sustainable management criteria being quantitative metrics by which we're assessing whether or not we're moving in the right direction to achieve the sub basin sustainability goal by 2,042. So of these six sustainability indicators, four of these rely only upon, observed measurements.

So that means groundwater level measurements or other kinds of physically based measurements. So for the groundwater lowering, we look at groundwater level measurements, groundwater quality degradation. As an indicator, we look at groundwater quality, from samples, you know, from a a collection of wells within the groundwater quality network. For land subsidence, we look at NSAR data and also groundwater level elevations, and then seawater intrusion, also looking at at water quality. One of the indicators we look at both observed, so physically based measurements, and modeled measurements, and that's for the depletion of interconnected surface water, ISW for short, where we look at groundwater levels in eight monitoring wells, and then we also look at modeled conditions to look at and assess streamflow depletion.

For the reduction of groundwater storage sustainability indicator, that is the only one that is based only on a simulated estimate of groundwater extraction over a period of time of seven years to look at an average amount of extraction that's occurred over that period. So when we turn to groundwater levels and what we're looking at over time with trends and levels in the sub basin, This graphic is showing by color coding, cooler kinds of colors are going in the direction of or being better than what we're referring to as the measurable objectives. So that's a good thing. The warmer colors, yellows to dark red, are going in the direction of, moving towards or exceeding the minimum thresholds, and and that's not a good thing. It's not necessarily terrible, but it means that there's reason to be assessing what's occurring to have caused the exceedance of a minimum threshold.

So when we look at the fall water year 2025 groundwater level measurements, many wells showed progress towards achieving or even exceeding a measurable objective for the groundwater level sustainability indicators. And we look at the image on the right, and we see a number of the wells that are in the central to the northern part of the sub basin showing that lighter green to the the light blue colors. When we look at the southern part of the sub basin, we see, warmer colors, and in particular, there are two wells that have exceeded the minimum thresholds, and these have occurred in the Northeast Napa management area. This is a very specifically defined area that exists within the sub basin, and it is defined based on very unique geologic conditions. And it's an area of concern where groundwater management needs more attention.

In this area, we see the two Napa County wells that are monitored, one hundred twenty two and two twenty nine, that have exceeded the minimum threshold. And in this slide, a little bit more on that. We're showing here the fall groundwater levels for 2023, '24, and '25. And in this case, we see these two wells that were exceeding the minimum threshold. In the case of Napa County 122, the current year is exceeding the minimum threshold by about six feet.

And in the case of Napa County 229, we're exceeding the minimum threshold at nearly 18 feet. In the case of 02/29, this is the third year of exceedances. Now, even though these are occurring, they are in this specially designated littoral formal management area. So that does not mean that this is representative of the entire sub basin. This means that it's representative of specific conditions in this Northeast Napa management area.

So as you've heard described previously, there's more of a thin veneer of alluvium that overlies more consolidated rock from which water supply wells produce groundwater in this area. There's also a fault that borders the eastern part of the sub basin and is adjacent to the Millikan Sarco Toluca area, the Soda Creek Fault. And there is also a fault that parallels the Napa River just to the west of this Northeast Napa management area, the East Napa River Fault. So these faults also constrain the flow going into this area, and it creates a longer time for replenishment to occur in response to the groundwater extracted from the more consolidated rock within this area. So when we turn to the interconnected surface water and looking at stream flow depletion, As I mentioned a moment ago, in this case, there are two, kinds of indicators that we look at that have sustainable management criteria, and these include groundwater levels at eight shallow representative marring well sites.

Now this is an increase in the number of wells that are being monitored. There used to be five sites, but there's been a number of newly installed monitoring wells, for the purpose of looking at stream aquifer interaction. So now there are eight sites that we're looking at. And we look at these relative to a defined minimum threshold that represents a minimum static water level within the base period during 02/2014. We also look at a volume of depletion occurring during the period from June to October, which is a more sensitive period that was chosen during the development of the GSP because of the kinds of beneficial uses that can be impacted during that period.

So we're looking at a volume of streamflow depletion, and this is based on using the modeling. And we're looking at what is the condition of the stream system when there's no pumping, and what is the amount of depletion occurring when there is pumping. Now, this volume of streamflow depletion is defined as an interim minimum threshold. There was a lot to be looked at with respect to the kinds of beneficial uses occurring within this period that was selected at the time that the GSP was being developed. So we'll talk more about that in a minute.

On the groundwater levels, this just summarizes what I was describing with the levels. We had these eight monitoring wells that are listed in this table, and we had no exceedances of the minimum threshold at any of these locations. When we turn to the streamflow depletion computation, Here, have a different situation going on where we have the, two stations, The US geological survey stations, Napa River at Oak Knoll and Napa River at Pope Street, and there's the defined minimum threshold on the left turn column under the heading representative site. And then we're comparing that to the modeled seasonal depletion during that June to October period. And what we're seeing for water year 2025 is that we have a minimum threshold exceedance at both the Napa River at Oak Knoll sites and, Pope Street site.

And in these cases, we also have, exceedances in water year 2024 at both of these sites. And at the Oak Knoll site, we also had an exceedance during water year 2023. So the sustainable management criteria also define an interim undesirable result as being the conditions that occur when we have, three consecutive exceedances of minimum thresholds at either one of these sites. And in the case of Oak Knoll, that did occur. So one of the things that we talked about last year was that there was more water in the system because we had a normal but below average year.

And when there's more water in the stream system, there's more water able to be depleted. So our volume of streamflow depletion goes up. But we wanted to look at this more closely because there's some other things occurring. So I'm gonna walk through various parts of this slide, which has a lot of different things going on. So in the upper left corner of the slide, we have a graph that's showing when we have the modeled stream flow altogether occurring when there's no stream flow, sorry, no pumping.

The stream flow condition is that top black line showing the amount of stream flow occurring over this June to October period. And when there's no pumping, we also see how much blue is shaded under that black line. All of that volume under that black line is the stream flow that could occur without the pumping. When we look at the stream flow depletion volume, that's that shaded red part, and that's how much, the volume that's being removed from the system through stream flow depletion. We've summarized again just here for comparison the June to October minimum threshold exceedances for 2024 and 2025.

And what we did here was then narrow our view so that we looked at some other months when there was less likely to be storms occurring, more water in the system, more water to be depleted, but that wasn't necessarily concern to the beneficial users within the stream system. So we narrowed our view to looking at July, August, and September. And when we look back at the base period from 2005 to 2014 and we look at the average of percent depletion, how much is being depleted relative to that stream flow, we see numbers ranging from 77% to 90%. But notably, in those months during the base period that we're defining as sustainable, because it's from 2015 forward in time, we're seeing that five to six of those ten years in that base period were a 100% depleted during the base period. So then when we look at water years 2024 and '25 and we look at that percent depletion and we look at water year 2024, in July 2024, we had a lesser percentage of depletion than when we look back at our base period.

We had higher amounts of depletion in August and September. When we look at water year 2025, we see even less of a percentage than last year 2024 and compare to the base period when we look at the percent depletion in 2025. So then even more importantly, when we look at measured streamflow, July, August, and September, and we compare water year 2024 to water year 2025, we see significant differences as an increase in water year 2025 compared to water year 2024. So we have more water in the system in 2025 than we did in 2024, and we also had more streamflow depletion in 2025 than we did in 2024. So the bottom line for the moment is that we're benefiting a lot from the work of NAPA RCD and Stillwater Sciences and the wet dry reach mapping that's occurring at six intensive survey sites along the Napa River system as part of the implementation of the interconnected surface water and grower dependent ecosystems work plan.

And I want to circle back to the GSP regulations that define what this interconnected surface water criteria must do when it was being defined. The regulations required that we had to have a rate or a volume of depletion caused by groundwater use that has adverse impacts on beneficial uses of surface water and may lead to undesirable results. So we, Napa County, and for the Napa Valley sub basin, was one of the very few sub basins that met this criteria literally that's in the GSP regulations. Most sub basins defined a proxy by using only groundwater levels to measure the sustainable management criteria for interconnected surface water. Importantly, as part of the interconnected surface water and ground independent ecosystems work plan, we had integrated the California Environmental Flows Framework into the GSP, and we integrated it into the work plan.

And the reason for that was we had defined the sustainable management criteria for streamflow depletion as an interim measure, recognizing that there was more to be understood about the relationship between the needs of the groundwater dependent ecosystems and the flow in the system. So we're needing to know what's the effect of depletion on the functional flow needed to support healthy groundwater dependent ecosystems. So this is an area that we're going to be focusing more on as we develop the periodic evaluation, which is due to the Department of Water Resources in January 2027. So turning now to another sustainability indicator, the reduction in groundwater storage. Here, the minimum threshold is the extraction exceeding by pumping, exceeding the sustainable yield for the sub basin where the net groundwork extraction is that volume that's extracted less any actual measured augmented recharge achieved by implemented projects.

So we're not talking about natural recharge. We're talking about specific quantifiable projects. And then when we talk about an undesirable result, it's that result where the seven year average annual net grower extraction exceeds the sustainable yield. So here we have an undesirable result that has occurred. It occurred last year as well.

We have six years where we've exceeded the sustainable yield that's estimated to be the 15,000 acre feet per year. Even though these are exceedances, it is very notable that there was that very dry period, 2020, 'twenty one, and 'twenty two, Even though 2022 had higher precipitation, it was a very oddly distributed precipitation and really hotter, drier temperatures. So those years contributed to much more pumping compared to more recent years. And the more recent years are moving in the direction of sustainable yield over a longer period of time. Three other sustainability indicators are water quality, seawater intrusion, and subsidence.

Water quality, we had one representative monitoring site well that exceeded the minimum threshold for arsenic. And this was in an area where arsenic has been historically detected for naturally occurring reasons. So it's not a condition that's attributed to groundwater management. Similarly, there's one represented mooring site well where the minimum threshold was exceeded for TDS. That was also a naturally occurring condition and not affected by groundwater management.

For seawater intrusion measures, we see high TDS in the tidally influenced area of the Napa Valley Sub Basin, and there is no minimum threshold exceeded. And for subsidence, there was no notable subsidence that's occurred and no minimum threshold exceedances. And this is really very little concern for potential for subsidence, especially because of the criteria that are needing to be met for interconnected surface water and keeping groundwater levels quite shallow. So in summary, we have average groundwater pumping over the seven year period where an undesirable result occurred for the reduction of groundwater and storage. And we have the seasonal streamflow depletion volume that exceeded the interim minimum threshold three times at the oak noll gauge, and that meets the definition for an undesirable result.

We mentioned a number of factors related to that that we're going to be exploring further. And one of the things that both of these conditions result in is taking a closer look at, well, what are the response actions in order to address these conditions and ensure that the subbasin is moving in the direction of achieving the sustainability goal. So this slide summarizes response actions that are in progress for both of these sustainability indicators. We have the interconnected surface water and grower independent ecosystems work plan that's being implemented, and we have monitoring going on at six sites that Esther Adelstein is going to talk about in a moment. And these are aquatic and terrestrial GDEs.

We've expanded the interconnected surface water monitoring network to include eight 28, additional monitoring wells. We've expanded the wet dry reach mapping that RCD is doing along with expanded stream dissolved oxygen and temperature monitoring. We are in the process of reactivating five historical US geological survey stream gauges through the support of a DWR CalSIP grant. And we're in the mode of implementing the California Environmental Flows Framework to help refine sustainable management criteria. For the chronic reduction in groundwater storage, here we began implementing the groundwater pumping reduction work plan.

And one of there are several things going along in parallel coming out of that. One of them is the development of a water certification partnership pilot concept, where there was an RFQ distributed, responses received, and Napa County Groundwater Sustainability Agency is working to partner with existing certification entities. There's also the development of a vineyard replant strategy concept, and that will receive further discussion related to some recharge interests at the June tag meeting. There's been promotion of water conservation as a Napa way of life since March 2024 when we first talked about that. And then most recently, there's been the release of the public draft water availability analysis guidance document and technical report for review and feedback, and that was at the March.

One of the things that the Department of Water Resources pays special attention to is tracking how subbasins' basins are doing with regard to the requirement to achieve their sub basin sustainability goal within twenty years of the submittal of their GSP. So for the Napa Valley sub basin, that's 2042. And annually, there must be a description of the progress occurring towards GSP implementation. Beginning this year, DWR as of April 1 this year, just a few days ago, DWR requires GSAs to upload a template that goes onto DWR's website. And this is one of the things that DWR will utilize to summarize and further track what's occurring with respect to GSP implementation.

So there's ongoing GSP implementation. The annual report was submitted to DWR on April 1. It's it's on the department's website and is accessible to the public. It's also posted on the county's website. We also put together a public friendly executive summary.

That was in the tag packet, and it's also posted on the county's website. There's, within the annual report, there's a very comprehensive interconnected surface water and grower independent ecosystems monitoring report that Esther's gonna talk about in a minute. And then we are in the mode of continuing to refine the NVIHM model, and updates will be talked about in June, along with some additional information on the recharge feasibility scenarios and implementation of the California Environmental Flows Framework. And that concludes my presentation. I'd be happy to answer any questions.

Thank you. Comments from TAG members?

So just going back to the stream depletion because it seemed that that was a complicated topic and a complicated slide. But is your did I understand correctly that we think this interim you think this interim MT is not the it's likely not the right metric to use moving forward?

Is that

We think that there's a complement to it. So one thing in and of itself, one, because it's required in the regulations, and then the complement would provide important contextual information to what does that mean relative to the actual or potential adverse effect on beneficial uses or users at what point in time? So we're trying to look at the GDE life stages. You know, what is their environment within the Napa River system? How did it how does it affect them where?

And what might be actions to occur to help support that that is actually can be implemented by the GSA because there's the overlying issue of climate effects as well. So one of the things is looking at how to keep more water in the system. So even if we get more depletion, we if we can measure more water in the system, yeah, then there's that, you know, understanding, you know, if that's enough to support the the the beneficial users.

And do we expect the periodic evaluation to is that at that point that there will likely be a re a complement or a revised criteria?

It would probably be, recommended additions to continue to assess because we probably won't have the end all answers within this narrow time frame. Some of the monitoring newly installed monitoring wells don't have that much of a record. There are especially the CalCEP five, you know, reinvigorated, installations that had historical records, and now we're going to have new records. But it will take some time to establish the rating curve and then actually collect data at those locations and, you know, synthesize that with the other data.

Thank you.

Other comments?

I also wanted to ask a bit about the storage and the over the seven year and being over 15,000 and kind of putting it in context that we are in 2026 and we are looking at getting to sustainability in fifteen years from now, which is both far but also coming pretty fast. And the fact that we are I mean, when we look at the average here, it's like 17,000, I think. So even if we reduce by 10%, we would still be above the 15,000. And so I'm curious to hear if there are other if that means I mean, if that if that changes anything to the current action or the current objective of the 10%.

Yeah. It's a good question. Several several things are going on surrounding that. So one is that it's, a modeled estimate. The model is being refined, So that refinement includes a number of things, including adjustments to the subbasin boundary, which was corrected in fall twenty twenty five by the Department of Water Resources.

So that's just slight. I mean, there are not large changes in that. It's slight. And there are the channel configurations over time that are being refined in the model. There's the crop coefficients, you know, information through open ET refinements to water use in the model updates and land use to current.

So they've been updated many years, but but not all the way to 2024 and and beyond. So there are a number of things going on with that. There's also the complement of groundwater levels and measured streamflow and how everything fits together. So the estimate of the sustainable yield within the groundwater sustainability plan was a range of 13,000 to 17,000, and 15,000 is the average. The other thing that I meant to mention about the model refinement, which is probably the most significant thing, is that there's being completed now, and then the model is gonna be recalibrated with all these different things and and more that I just mentioned.

And it includes the tracking of soil moisture within the subsurface instead of an an instantaneous movement of the infiltrated water to the groundwater system. So it's an important aspect of, vineyard management practices depending upon how water is occurring within the year and the moisture within the soil column and what needs to be watered when or what can be delayed, all those kinds of things. And so we expect there will be refinements, you know, to what we're seeing in the way of the sustainable yield. It could be less or it could be more. It could go either direction.

But I think the physical measurements, you know, groundwater levels and stream conditions and what can actually be done to, you know, move conditions by the GSA in those, you know, mediums in order to achieve sustainability.

So it's clear we do expect also a refined estimate or an adjusted estimate of the sustainable yield as part of the periodic evaluation?

Probably. Yes. Because we also need to look at the climate projection with whatever can be, you know, utilized on that scale, which is always, you know, maybe chasing the ball, you know, that's already changed before, you know, before it changes again.

And then once those refinements are made to the model, then there, if relevant, were applied retroactively? Or do you just use them going forward?

It would be looking over that whole base period again. So it would just provide new insights as to how things may have shifted in the various water budget components.

I guess what I'm asking is you realize something in your modeling needs to change in 2026. You go back to 2022 and then make any corrections, or does that only stand going forward?

So any change in the model now affects the simulation over that entire base period. In essentially, it's all refreshed.

Okay. That's what

I was

trying to make sure.

And here we see in the table of sustainable yield 15,000 acre feet and what the actual estimated groundwater extraction was. So if we have exceeded that six years out of seven, are there resulting impacts that we can point to and measure? How can we sort of verify that we really have been taking too much if this is the case?

Well, the thing that we see from the slide that I showed with the groundwater level elevations for fall and then the color schematic go back to no. That's all right. I'll just describe it. The colors between the measurable objective and the minimum threshold. And then the central to the northern part of the basin, we were moving towards the measurable objective.

Or in some cases of the sub basin, we were exceeding the measurable objective. So in those areas, we're essentially meeting what we had defined quantitatively to achieve in some areas. However, in the the more southerly part of the Subbasin and especially in the Northeast Napa management area, we're seeing, you know, moving in the other direction, you know, some going towards the minimum threshold or exceeding it. So those are the main indications of where a little bit of exceedance over that sustainable yield is showing up in the physical measurements of groundwater level elevations at that fall period.

Okay. And then that raises questions about the Northeast Napa area and how much that should be weighted and so on.

Right. And we're trying to it it does not represent the whole sub basin. So we're trying to look at that as its kind of unique place to manage, you know, what's going on with groundwater extraction there. But we also had some levels within that more southerly part of the subbasin that weren't doing as well as when we look to the northern part of the subbasin.

Right. So it could be interesting to look at that those data or that map as how those individual sites have changed over time too, right? Because we're just seeing the 2025 and where they are, but how they have changed either in the positive or negative.

So in this,

Yeah. There are a lot of hydrographs.

So this is actually 300 pages less than last year's. It we have work plans that are now not part of this because they were done under the last, what year, 2024 and referenced online. Yeah.

Yeah. Maybe just, like, next year when you get every report, we see not just this the current, but then also kind of the the shift through time?

Actually, we can put that on the list for the periodic evaluation and describe what's going on.

Vicki, one more question. Would it make sense, given that we are, for this sustainable yield, are comparing with a seven year average, would it make sense to also do the calculation of the cumulative groundwater storage change based on the water level and show it over the same seven year period?

Potentially. So the fall the conversation we were having a second ago about the fall groundwater levels, That is, the basis of the sustainable management criteria definition for the lowering of groundwater levels. And so we could also look at what's going on with respect to changes in the network, wells that are for that change in storage in the spring and what kinds of increases we're seeing over time and how much it can actually be shifted. I think a big part of it would be to look at those levels that are also being used together with the streamflow depletion volume that are indicative of how discharge we're trying to see from the groundwater system into the stream system.

When you're presenting us with the historical precipitation, it's it's strictly an amount. I think in the past, we have seen more of a seasonal trend in when that rainfall because to your point, when we're modeling both vineyard water use and natural vegetation water use, It's not just amount, but timing of rainfall. It may be in the big book. But I think as part of these presentations, it would be useful to see how the pattern of rainfall had shifted, stayed the same, you know, over the years, and as part of, like, our understanding of each water year as well.

Okay. So what yeah. We do have a figure in the report that shows, specifically, water year 2025 by month and the amount of precipitation occurring. We might be able to figure out some ways to do some comparisons, I'm sorry, on a figure to show some illustrations of how things are shifting, water year 2022 being a prime example of, yeah, how we had a lot of rain and then we had nothing. And so that mattered a lot. Yeah.

And that's part of the ship. Right? It's not just the amount of rainfall that we're getting, but when are we getting it? Right.

Right. Like that would be very useful. Stacked graphs of precipitation over the year for the last seven years or something like that to capture October 2021 kind of events. Yes, it would be good.

Good idea.

Any other comments from the TAG? All right. Think we turn to public comments.

Hi. Michelle Benvenuto, wine growers of Napa County. The 2025 report shows once again that the minimum threshold for the reduction of groundwater storage has been exceeded and that the seven year pumping of 17.7 acre feet per year constitutes an undesirable result. We have a fundamental and ongoing concern about what these findings actually mean and whether they accurately represent the conditions in the sub basin. Let's start with what the report actually did observe.

Ground groundwater storage increased by five eighty acre feet this year. The cumulative change in storage since 1988 remains positive, and only two representative monitoring sites exceeded the groundwater level threshold, and those were both in Northeast Napa Mansion area. So by observed results, the aquifer is not in crisis. So why do we keep having these undesirable results? It's because of what you guys were just discussing, the sustainable yield at 15,000 acre feet, which was reduced 25% from prior estimates based on modeling refinements, not observed aquifer decline.

The minimum threshold is being triggered by a number that may not accurately reflect what the the sub basin can sustainably yield. Per the executive report in this, for the twenty twenty five states, quote, the computed groundwater pumping average, which is defined as an undesirable result, does not represent a concern, but it does indicate the importance of groundwater management approaches. Additionally, there is a troubling pattern. The undesirable result for groundwater storage is based entirely on modeled extraction compared to modeled sustainable yield. The interconnected surface water indicator relies on model results to translate pumping into streamflow depletion.

And the two wells showing observed exceedances sit in one management area where the model was most heavily revised. The areas where modeling assumptions change the most are the areas showing the most concerning results. Meanwhile, the broader sub basin where data is actually reported and observed is trending towards recovery. And this doesn't just impact the GSP implementation. The sustainable yield is the direct mathematical foundation for the 0.5 acre feet per acre criterion in the 2026 WAA, which you guys will be reviewing today.

We appreciate Vicki's mentioning that the model is being refined, but we have been mentioning this for years, how concerning this is. And we hope that you guys will take it into consideration. Thank you.

You.

Thank you for that report. As always, very good. I'm Paul Brophy with EGS. Two quick comments. I think this is the fourth annual report, and I haven't seen in any of those reports any work being done on the actual aquifer itself, the groundwater system, other than the the wells that were drilled by the county looking at streamflow effects.

These these wells are very shallow, and they're certainly not wells that you would cite in that location if you're looking to further understand details of the aquifer itself. One other quick question. I just was wondering how you incorporated the absence of data from Napa hospital site into the calculation. I think there was somewhere between about twenty eight and thirty days during the twenty twenty five that had no data from them. And even now, you can see a fairly significant discrepancy between what they're reporting in the newspapers as rainfall and what we're seeing from different sites around the area.

So did you make an adjustment for that absence of data? Thank you.

Thanks. Other comments?

We have one caller. David, you will have three minutes.

David, I see your microphone volume adjusting, but I don't hear you. We still can't hear you, David. Still don't have you. Maybe we can jump over to Matthew Connor, who just raised his hand. And David, if we can get your volume fixed, you can ask your question after.

Matt, are you there?

Matt, can you hear us, sir? Having little tech glitches. Let's see if we can get you guys to be able to be heard in the room.

David, are you there? Yeah.

Now we can hear you.

Okay, great. I have, as I have been saying earlier, a host of questions, but I will limit it to two. First question is, or an observation, it seems to me it would be useful to calculate a very widely used plant physiology metric known as vapor pressure deficit. I don't know how many stations you have access to, but certainly the western weather stations would be a very easy way to calculate that in a pretty fine grained manner. And it's a very direct notion of how plants are interacting with the atmosphere.

So that's not rocket science, I don't think. Second question would be, I think there was some discussion about having access to soil moisture data. And it seems to me that one interesting metric would be to graph the soil moisture changes in various seasons as a means of accounting for some of the things like, did it rain a lot early and then not rain much later on, etcetera, as a way of characterizing in a more fine grained manner what each winter precipitation season yields in terms of soil moisture conditions. Thank you.

Matt, you will have three minutes.

Thank you. I don't have any questions or comments at this time. I was getting in the queue there to let you know that we could hear David Graves and you couldn't.

Thank you.

Thank you. We have no other callers.

I think then we could move on to thank you, Vicki move on to an update on interconnected surface water and groundwater dependent ecosystem work plan implementation and a focus on the results of the twenty twenty five monitoring.

You. Hi everyone, my name is Esther Adelstein. I'm a hydrologist at Stillwater Sciences and I've been working with Christian Broderick on the NAPA GSP project since development of the interconnected surface water and groundwater dependent ecosystems monitoring plan. Today, like Matt says, I'm gonna be presenting on work plan implementation monitoring results from 2025. The monitoring was a joint effort by several groups, and a lot of the data I'm gonna be talking about today were collected by the NAPA RCD and Napa County, as well as Ludorff and Skalmanini and a team of biologists from Stillwater Sciences.

The objectives of the groundwater dependent ecosystems monitoring are to assess what ecosystem components or species are present at intensive monitoring sites, and to help characterize groundwater and surface water dynamics at each of these sites. And the results of monitoring are going to be applied to assess what the biological flow and groundwater needs are for each ecosystem component. And as Vicki mentioned earlier, we're going to be doing that analysis using the California Environmental Flows Framework or SEF to assess ecological flow needs. And that analysis is going to be conducted as part of the periodic evaluation, and there'll be an update on that in the June meeting. So today, I'm gonna be presenting on the results from monitoring year 02/2025.

We're currently in monitoring year three. In monitoring year two, monitoring included stream watch observations of in channel flow conditions, shallow groundwater monitoring at dual completion wells near the ISW GDE sites, fish snorkel surveys, remote sensing for groundwater dependent ecosystem vegetation health, fish habitat and usage surveys, aquatic life surveys with aquatic wildlife surveys, which included surveys for special status species, which are California freshwater shrimp, foothill yellow legged frogs, and the Northwestern pond turtle. Based on 2026 precipitation to date, This year is a dry year, but not a very dry year. So we're not going to be doing the optional monitoring next year for aquatic wildlife. Sorry for this year or for vegetation health and rare plants.

Finally in 2025, we conducted the first round of bird surveys at the intensive monitoring sites. And to get a second year of data, we've pushed the bird surveys back and we'll do a second round in 2026. So the work plan identifies six intensive survey sites. We have four on the main stem and two tributaries. The main stem sites are the Napa River at Calistoga, at St.

Helena, near Yountville, and at Oak Knoll. And the tributary sites are Sulphur Creek and Bale Slough. This was the first year we had access for all surveys at Napa River at Oak Knoll and Bale Slough, so we'll have results from all six sites for 2025. This year, Stillwater led three field trips, which included members of the TAG and the Napa County GSA. And we've already seen this figure, but climate is an important driver of conditions for ground dependent ecosystems.

As Vicki mentioned, annual precipitation in the southern part of the basin at Napa State Hospital, which is shown in this plot, was below average. But precipitation in the northern portion of the basin was wet relative to the historic record. And that's attributed to an atmospheric river in early water year 2024 in November that dumped about 17 inches of rain over two days. In early summer twenty twenty five, that should say June and July, August, June and July, not July and August, were relatively cool compared with the historic record. So consistent with more precipitation in the upstream reaches of the basin, the main stem was generally wetter in 2025 than 2024.

The USGS gauge at Oak Knoll did not go dry this year. Last year, went dry in 2024. Sorry. It went dry in September. The Saint Helena gauge was flowing until late August twenty twenty five compared with 08/08/2024.

The plot on the upper right shows the results of dry season flow connectivity surveys or wet dry mapping at each of the sites. The y axis shows the percentage of the reach length that that was wet, and the x axis shows time. The dashed green lines are the 2025 results, and the solid orange lines are 2024. In general, the Calistoga and St. Helena sites remained wetter through 2025 than they did 2024.

The Oak Knoll and Yountville sites were both flowing year round, and the two tributary sites tended to start getting really dry in August. The plot on the bottom right is courtesy of Nick at the county, and it shows dissolved oxygen at the St. Helena site. The shading in the back shows suitability criteria for juvenile steelhead, where green is generally good and red is generally bad. Save for maybe the first half of June, temperature and dissolved oxygen were generally stressful for steelhead, both at this site and throughout the watershed.

So this is a summary of our 2025 biological survey results. We saw juvenile steelhead on the Napa River at St. Helena and at Sulphur Creek, and we saw adults at the Yountville site. Juvenile Chinook salmon were observed at all sites this year, which is a pretty big contrast from 2024, and we didn't see Chinook in the watershed. Foothill yellow legged frogs were observed only in the tributaries, so at the Sulphur Creek site, and also at Dry Creek, which is adjacent to the Oak Knoll site.

We saw a Northwestern Pond Turtle at Oak Knoll, and turtles were also detected in eDNA sampling at St. Helena. We identified over 59 unique bird species using sound recorders deployed at each of the monitoring sites. And those 59 species included one special status species on the Napa River at St. Helena, and that was a northern yellow warbler.

Vegetation surveys found minor vegetation stress in mature trees on the main stem, but otherwise no significant signs of vegetation stress. For the rest of this presentation, I'm going to discuss select survey results. We'll start on the main stem and work our way down and then go to the tributaries. And this is going to focus on the two new sites this year, were Oak Knoll and Bail Slough. The Napa River at Calistoga is critical habitat for California freshwater shrimp.

And this year surveyors observed 123 shrimp in isolated pools both along the main stem and in Garnet Creek They were observed in those yellow rings on the map on the right. And we saw a good mix of males and females, and a mix of age classes indicating that the population is reproducing successfully in this reach. We also saw a lot of juvenile Chinook at the Calistoga site this year. Now we'll move downstream to the St. Helena site.

The map on the right shows results of wet dry mapping from 2025. For the wet dry mapping or flow connectivity surveys, the RCD walked approximately one mile reaches at each site, recording with the GPS where the channel was wet, where the channel was dry. The blue reaches on these maps are wet, the red reaches are dry, and the yellow shading is the extent of the longitudinal topographic profile that were surveyed in 2024. So at St. Helena, the upstream section of the channel stayed wet through early August, and the Pope Street gauge was flowing until late August.

That reach had transitioned to isolated pools by early September. And the middle section of the reach, which started drying in August, was dry by September. Further downstream at Oak Knoll, wetdry mapping shows that the site was flowing year round, consistent with the USGS gauge. We also observed beaver dams at the downstream end of this site. The plots on the right show temperature and dissolved oxygen monitoring results from the Napa River at Oak Knoll site.

The plot on top shows water temperature. We deployed two loggers this year, oak one and oak two, which are the black and blue lines. One was at the middle of the reach and one was at the upstream end of the reach. And once again, the shading shows habitat suitability criteria for steelhead. Green is good and red is bad.

Temperature and dissolved oxygen were both somewhat suitable for steelhead in early June, when flows were still high and temperatures were still relatively cool. But over the course of the summer, water quality got more stressful, particularly for juveniles. These conditions are similar to what we observed at the Napa River at Yountville, where despite the reach flowing year round, temperature and dissolved oxygen were generally in the stressful categories. Okay. And our biological surveys at the Oak Knoll site found incidental numbers of fish.

We saw two adult oomycous and one juvenile Chinook, but we don't think that fish are using this reach very often. Northwestern pond turtles were observed at this site in June, and Foothill Yellow Legged Frog were detected in eDNA at this site in June. That we think was likely just a hit from frogs in Dry Creek, just upstream of the site. And our surveyors revisited the site as well as Dry Creek in July where they did find foothill yellow legged frogs. Now we'll move on to our tributary sites.

This slide shows wet dry mapping at Sulphur Creek. The dash teal line that is hard to see on this slide shows the sub basin boundary. Consistent with 2024, the reach within the groundwater basin began to dry by June starting at the downstream end. And it stayed wet at the Heath Canyon Confluence, which is just upstream of the basin boundary year round. And you'll notice also that dry segment at the very upstream under the reach starting in July.

And that we think is due to dewatering associated with the fish passage restoration project that was implemented in June. This plot shows groundwater levels and stream watch observations at Sulphur Creek. The black line is the groundwater levels. The orange line is the channel thalweg as surveyed in 2024. And the shading in back is stream watch observations.

Green is flowing, blue is isolated pools, and red is dry. In general, the water table was below the thalweg throughout the monitoring period. There is some uncertainty associated with that. The the well is about 200 feet from the thalweg. But in general, we think that a groundwater connection is unlikely at this site based on data to date.

And that's also supported by vegetation observations at the site. Our surveyors found primarily upland and riparian herbaceous species that are not likely to be groundwater dependent. Now we'll move on to the results of biological surveys at Shelfir Creek. We saw a lot of fish. The two maps in the middle show the locations of juvenile steelhead observations in May and June 2025.

May is on the left, June's on the right. Over 700 juvenile steelhead were observed in May throughout the reach, and over 200 were observed in June with observations concentrated farther upstream as the downstream end of the reach began to dry. Juvenile Chinook were also observed in this reach. As far as amphibians go, Foothill Yellow Legged Frog egg masses were observed in April, and tadpoles were found in April through June. Additionally, over 1,400 frogs were relocated during that June fish passage restoration project.

This slide shows the results of wet dry mapping at Bale Slough. Similar to Sulphur Creek, the site dried from downstream to upstream. It was had transitioned to isolated pools by early June and was mostly dry by July. This site is a restoration reach, and restoration in this reach was completed in 2023. Here we have groundwater levels and stream watch observations at Bale Slough.

Bale Slough dried as the water table fell below the channel fall wag. So based on two years of data, it's likely groundwater dependent. There were only a few fish observations at Bale Slough, and it's been determined to be a likely migration reach, but doesn't provide good habitat itself. No special status amphibians were found in the reach, but there is a beaver pond at the top of the site. Okay.

And here are those water quality plots again for Bale Slough. You can see that temperature and dissolved oxygen were somewhat suitable in early June, and we did see several juvenile Chinook at the site, but no steelhead. But they quickly got stressful shortly thereafter until the site went dry in early August. In general, we don't think this site provides great habitat for salmonids. Our survey is planned in 2026.

The RCD and county, I think, have already deployed oxygen and temperature sensors for 2026, just in time for rain this weekend, but it'll be nice to get some springtime water quality data before things start to get really bad. We're gonna do another round of wet dry mapping. Everyone loves wet dry mapping. And RCD is gonna keep doing fish population surveys this year. On the Stillwater side, Stillwater has deployed audio recorders at all six sites.

We put those out in June. And our amphibian folks are going to be going back out to Oak Knoll and Bail Slough to get a second year of data, since last year was the first year we could monitor at those sites, and they'll be heading out next week. So the goal of the ISW and GDE work plan is to better understand the conditions required to protect and enhance healthy terrestrial and aquatic GDEs. So based on 2025 monitoring, current conditions include abundant juvenile steelhead on Sulphur Creek, water temperature and dissolved oxygen that are generally stressful for steelhead at all sites, but slightly better earlier in the summer. And based on two years of data, we see that there's plenty of year to year variability.

We saw a lot more Chinook in 2025 than in 2024. And slightly higher flows and cooler air temperature may have led to better water quality in early June twenty twenty five. In 2026, the periodic evaluation will synthesize the results of 2024 and 2025 monitoring and apply them towards the CEF analysis to help better characterize habitat requirements and flow ecology relationships at the six sites. Thank you. And we can take any questions.

Thanks. Comments from TAG? Well, just one quick comment. It's great to see this coming together. And as you know, a lot of maybe unexpected variation from year to year.

And so as we see that playing out more, that will be, I'm sure, give us some new insights into some of these relationships. I'm not sure that I have other comments. Julie?

Yes, just a quick question. Is there anything that we are that the team is adjusting or changing based on the results of 2024 and 2025 in terms of what is monitored or how how it's done?

I think the big one is getting the water quality loggers out earlier in the year to potentially capture what things look like when water quality might be better because the tiers of monitoring have showed us that it's generally not great in summer. Yeah.

Okay. We could take questions, comments from members of the public.

David, you will have three minutes.

Thank you. Am I audible?

Loud and clear.

Okay. Great. First question is about vegetations, the the water status of riparian vegetation, is that a usefully measured with sequential NDVI road sensing data? That's perhaps a question to be answered later. This is an editorial comment.

Second, I'm a I'm a big bat advocate. And this a very similar technology, almost identical to the bird call technology, could be deployed to to understand more about the bat fauna. Probably has a different recording device tuned to 20,000 hertz and higher for bat calls. But I know that at in the one TAM biological monitoring process, they have had great success with the same kind of recording technology that I believe you're using for the birds. So if you're already deploying those, it seems like you could just attach them to the same thing you're attaching the the recording devices to for the bird census, and you would kill, no pun intended, two birds with one stone.

Sorry. That's a terrible joke. So those are my two observations. Thank you.

Thanks, David.

We have no other callers.

Okay. Yeah.

So that comment then reminds me of one thing that came up during one of the field trips, which was aquatic invertebrates and because bats are insectivorous, right? And where we stand on doing those types of surveys.

I don't know the answer about benthic macroinvertebrate surveys, but I will make a note and ask.

Okay. Well, you have preemptively answered all our questions and that has brought us back on time amazingly enough. So we could take our ten minute break now, and we'll be back on schedule. Thank you, Esther. So ten minute break, we'll be back at 03:20.

Welcome back. We can continue now with presentation on water availability analysis. Patrick Ryan and Vicki Kretzinger.

Chair, TAG members, it's a pleasure to be here today. I'm Patrick Ryan. I'm the assistant director of planning, building, environmental services. And to my left, you know Vicky from Ludorff and Scalminini. I'm pleased to present this TAG, this group, the 2026 Napa County public draft of the water availability analysis and supporting technical report.

This presentation outlines some of the updates that have been done and a little bit of background on groundwater management in Nabbit County over the last couple decades. This is a presentation. We do encourage feedback and comments from our stakeholders, our peers. As I said, this is a public draft document in public review. And any comments or questions, we have information on our web page in which our stakeholders, our community members can submit their comments to our department for review and to be addressed.

As I as I mentioned, today's presentation is going to outline Napa County's management regulations and policies throughout the years. We'll review the public draft and procedures and screening process that's been outlined in the draft 2026 WAA. We'll summarize those updates at the end of the presentation and talk about next steps. The principles embodied in the water availability analysis have been a cornerstone of Napa County's groundwater management since 1991. Originally developed during the 1990 drought and updated throughout the years in 1999 under the Groundwater Conservation Ordinance.

Then subsequently, a water availability analysis was developed in 2015. Since 2015, Napa County has seen many regulatory and policy changes related to groundwater management. Specifically in 2022, the Napa Valley Subbasin groundwater sustainability plan was adopted. In 2022 and 2023, governor Newsom executed executive order n 07/2022. In addition to that, the public trust doctrine and some case law occurred to reflect requirements related to groundwater extraction and public trust resources and other related actions in California related to groundwater conservation and natural resources conservation.

Today, on March 27, Napa County released the public draft of the 2026 water availability analysis guidelines and technical report for review and comments. What you have here today is a copy of the front page of the two documents in question. These are the public draft that was released to the public in late March. They can be found on our webpage at Planning, Building, Environmental Services. And again, we're we're going through a sixty day comment period which will close in late May.

The twenty twenty six updates to the water availability analysis addresses critical groundwater and interconnected surface water management considerations that have emerged since the origination of the WAA was first written in 2015. Some of the key updates include identification of four delineated groundwater areas with unique requirements. That includes the Napa Valley floor, the North Napa management area, the MST or groundwater deficient area, and then all other areas outside of what I've just mentioned there. The tier one analysis or groundwater use, updated screening criteria for the Napa Valley sub basin, and a streamlined methodology for estimating recharge in areas outside the Napa Valley sub basin. For the tier two analysis, which is the well in spring interface interference analysis, we clarified some methodologies for analyzing potential interference for those nearby and neighboring wells within 500 feet of your project well.

Our tier three analysis which addresses our surface water interconnection and our public trust resource obligations. We've implemented and updated and made improvements to create protective standards for groundwater extraction within 1,500 feet of significant streams, both inside and outside of the Napa River watershed.

You, Patrick. Vicki Krutzinger, Graberte. Continuing on, I'm going to provide some brief overview of the procedure and screening process for the draft 2026 WAA. So much like the 2015 WAA, there are specific locations called out groundwater areas that have various criteria that apply to specific groundwater use areas. And there are three tiers.

As Patrick just summarized, there are some updates and also refinements, and some of which are intending to help streamline and and accelerate some of the review process by planning, building, and environmental services and together with, you know, the requirements that the applicants are are following. So these include the extraction locations and then tier one, the water use criteria, including the recharge analysis for outside the sub basin, well and spring interference criterion, and the groundwater surface water interaction, or looking at the potential for streamflow depletion criterion. So on the extraction locations, historically, the water availability analysis documents had referred to the Napa Valley floor. But with the very specific requirements of the Groundwater Sustainability Plan and the development of sustainable management criteria that apply to the Napa Valley sub basin, we recognize the need to clarify the delineation of some of these locations. So starting with the Northeast Napa management area, that is within the overall Napa Valley sub basin area.

And on the image on the right, it's pointed out in that small area with the horizontal cross hatching. That is a very specific nomenclature, calling it the management area because because of the ground sustainability plan regulations where that identifies specific sustainable management criteria within that location and looks to projects and management actions and differences that may occur in water use and the geology, aquifer characteristics, and the like. So it was in 2017 that the county had initiated studies of this area, recognizing concerns about the available groundwater supply to be developed and the sustainability of that supply. And by 2018, it became named a management area. And then within the Groundwater Sustainability Plan, it was formalized again as a management area.

This is unique from the rest of the sub basin. And as we were mentioning earlier this afternoon as part of the annual report item, it is very geologically different in terms of where groundwater is produced from within more consolidated rock formation for water supply purposes. There's the fault along the east side of the Northeast Napa management area, the Soda Creek Fault that it, you know, is near to the Millikan Sarco Toluque area outside the sub basin. And on the West side of the Northeast Napa management area is the East Napa River Fault. So both of these faults constrain flows into this area, and there's also a concern about what is occurring with the groundwater production in this area, as illustrated by the two wells that we've been tracking with declining groundwater level trends that are completed in that more consolidated formation material in the Northeast Napa Management Area.

When we exclude that area as a very unique area within the subbasin and we also exclude that finger of the subbasin that extends into the MST, we have an area that we're referring to as the Napa Valley floor. Separate from that and outside of the sub basin is the Millikan Sarco Tulakay area. This was defined within the county's groundwater conservation ordinance in chapter thirteen fifteen. And it's specifically an area where the amount of groundwater is inadequate to meet the demands at a particular time. This has been an area that's been designated for quite some time as being deficient.

One of the things that's occurred is refining the delineation of the MST such that this area is entirely located outside the subbasin, doesn't overlap into the Northeast Napa Management area, and does not overlap into the subbasin. So there's a change of about 3,000 plus acres difference reduction in the extent of the Melican Sarco Toluque area so that it is entirely outside of the subbasin. Then all other areas that are outside the subbasin and outside the MST are just referred to as that all other areas. And here, we're zooming in in detail to look at what I was just describing with a little bit better view. We have the Northeast Napa management area, which is within the Napa Valley sub basin.

We have the MST area, which is outside the Napa Valley subbasin. There is that finger down along the Tulakay Creek drainage area on the southerly part of the MST that extrudes from the subbasin into the MST, that area follows the criteria that are established for the MST. So in the next few slides, I'm going to be talking about the tier one water use criteria. These are applied to the locations where the applicants have parcels, and there are different criteria that apply depending upon the areas that we just described as the Napa Valley floor, Northeast Napa management area, the MST, and all other areas. These groundwater use criteria are summarized within the Napa Valley, sorry, the water availability analysis guidance document.

And then there are additional details about the derivation of the water use criteria that are in the supplemental technical report. One of the things that Patrick mentioned and briefly referred to is the recharge analysis that is applied to the area outside of the Napa Valley sub basin. And I'll come back to that in an upcoming slide. On this slide and the next slide, we focus on considerations related to the tier one water use criteria, particularly within the sub basin. And at that point in time in June 2022, when those were interim water use criteria, there was a rough analysis that included the use of the sustainable yield for the entirety of the subbasin and the entirety of the mapped area of the subbasin.

Since that time, it has been refined to look more specifically at areas of groundwater use, and particularly, where we have, such as irrigated lands and or potentially irrigated lands. We have self supplied users, including residential, commercial, industrial, and open space. We also looked at how the sustainable yield applies to the Northeast NAPA management area. But in that area, it required a very specific analysis to look at what can that area actually support because of the declining groundwater level trends that we're seeing in that area. So in the technical report, there's a detailed analysis that arrives at a portion of the sustainable yield that is the overarching sustainable yield for the entire sub basin.

We also looked at the land use data related to what I just mentioned. It doesn't exclude the potential for future open space use to be developed. Includes consideration of that as potential future groundwater use. And then there's a current appropriate uses of groundwater by the city of St. Helena.

The city has a safe yield, in quotes, that it has designated, analyzed for purposes of the city, that it uses groundwater in conjunction with its surface water supplies, and that amount was 350 acre feet per year. That analysis has been recently updated and reported out to the city staff. So when we apply these things across the sub basin based on the sustainable yield of the 15,000 acre feet per year, which is the best available information at this point in time, recognizing that there are additional data continually being collected and refinements being made. So we've looked at the proportion of the groundwater use in the three areas, including the Napa Valley floor, excluding the portion that's the Northeast Napa management area and the part of the MST, the acreage associated with the Napa Valley floor, and minus the appropriate use for the city of St. Helena.

And that amount was 14,100 acre feet per year. In the Northeast Napa management area, our analyses of what could be sustained in that area indicate that it would be approximately five fifty acre feet per year within that area. And then the city of St. Helena, as I just mentioned, they have a, quote, safe yield of three fifty acre feet per year. So all total, that amounts to the estimated sustainable yield of 15,000 acre feet per year.

These criteria just apply to new and replacement well and new projects that come before the Planning, Building, and Environmental Services Department. Concurrently with that, as part of the groundwater sustainability plan and efforts to implement the groundwater sustainability plan, there are voluntary efforts that are being encouraged across the county, across the sub basin for water conservation as a Napa way of life. So as we turn to another part of the tier one process and this is specific to the recharge analyses for outside of the sub basin we've developed a streamlined method. And this is to look at the potential recharge that informs the estimated average of the annual groundwater use that can be supported outside of the subbasin. Previous analyses have sometimes used the recharge results that were developed as part of the county's 2013 updated hydrogeologic characterization that was conducted by Ludorff and Skalmanini consulting engineers, and MVK engineers.

That analysis was largely a simple water budget of the watershed. It was not considering geologic conditions. As we look ahead to the streamlined method, as I'll mention more about, it does incorporate more of the geologic information. One of the things that the county is attentive to are applicants' interests in trying to expedite review processes because this is an analysis that can be cumbersome. So as part of the streamlined method, it uses recharge estimates developed using the United States Geological Survey Basin Characterization Model, and also a ten year period of prism data for precipitation, and also information on slopes, particularly those that are less than 30%.

The Basin Characterization Model, the BCM, it's a simple grid based model, not too unlike what had been used previously in 2013. However, it also includes climate inputs and temperature considerations. But it was not so attentive to geologic conditions. So we had updated the Basin Characterization Model to consider more of the underlying geology and aquifer parameters, hydraulic conductivities associated with the underlying geology, and then reran the basin characterization model to look at the potential for recharge going into the subsurface to replenish the system. Now, involves spatial information that the county would provide on both the recharge estimate and the PRISM data over this ten year period and also the slopes.

The PRIZM data, it provides an an average over this ten year period of generally drier conditions that are more representative of conditions than if we looked at a a multi decadal period. It's also a more consistent way of estimating recharge over a specific period rather than accommodating various different approaches that might be employed without some specific guidance. All of these maps would be provided for site specific parcel analyses. So these are just generalized information. The county would have specific maps for each of these different data sets for applicants to look at their specific parcel for the recharge estimate and the precipitation and, slopes that are less than 30%.

Anything steeper than that is excluded with the idea that it's less likely to infiltrate, and rather it would be running off. Alternatively, if applicants find that this is not representative of their specific sites and they have additional site specific information that can refine their analysis, then they can elect to utilize a registered professional to do the analysis with some specific inputs. But with any site specific data, then it would entail providing and supporting thoroughly documented additional data to support the analysis of the recharge. Importantly, hillsides are vulnerable to hotter, drier temperatures. And recharge, you know, at the sub basin boundary, it's important in terms of sub surface flows into the sub basin.

The recharge at the higher elevations is very important to support healthy ecosystems and other land uses. For the land uses that rely on groundwater, the WA tries to incorporate procedures that provide reasonable information and the potential for replenishment of those groundwater resources. But the land uses in the hillsides are more more vulnerable to climate extremes. And in these hotter, drier times, it's not beneficial to count on water sources that are not available due to limited water supplies and fractured rock that are difficult to replenish. On tier two criteria, here we're looking at then the 2015 WAA included tier two analyses.

And this is much like that where it proposes wells to be located outside of a 500 foot radius of other neighboring wells. This graphic shows why that is. If you have wells in too close proximity to one another, then their cones of depression can intersect. The closer they are, the more opportunity there is for the pumping of one well to adversely lower the pumping level of the other well and potentially create an issue depending upon the significance of that effect. So the criterion here is met presumptively.

If there are no neighboring wells within 500 feet of the applicant's existing or proposed well. This for domestic wells, when there are new or replacement domestic wells planned to be located within 500 feet of a neighboring well, It's recognized that there's not as much pumping that goes on with the domestic well. However, it's preferable not to sited immediately adjacent to your neighbor's well. So it looks to what's reasonable and feasible in terms of siting it within the bounds of the property available. One of the other things that's occurred with the 2026 update is a clarification of the methodology for conducting the Tier two analyses.

There's some parameters that are laid out and criteria that are lined out, a framework for how the analysis is conducted. And this is done typically through a professional conducting the analysis. There's an appendix in the WAA guidance about this methodology. On the tier three analyses and criterion, the 2015 WA included the first criteria for consideration in groundwater pumping and the potential for streamflow depletion. And the twenty fifteen WA included analyses about site specific information to evaluate the degree of hydraulic connection to the river.

And these included such things as the distance to surface water, the depth of completion of the well or wells on the property, the site hydrogeology, and streambed properties. Now, this analysis has been recognized as oftentimes being very complex, very time consuming, and expensive to be able to calculate the potential effect on streamflow and to demonstrate that the project would not result in a significant adverse effect. The 2026 WAA requires information sufficient to support the groundwater sustainability plan and public trust considerations to ensure the protection and enhancement of groundwater quantity and quality for all beneficial uses and users of groundwater and interconnected surface water because the GSA needs to achieve the sustainability goal for the sub basin within twenty years of GSP implementation. The county needs to do its part for public trust to take into account as part of the permitting process and to facilitate the applicant's efforts to demonstrate that there's no significant adverse effects that would occur due to groundwater use near streams, the 2026 WAA includes new protective standards. So these new standards are lined out in great detail in three large tables inside the WAA guidance document.

And there's additional discussion within the technical report specific to some of these standards. One of the things criterion is presumptively met if the wells for the applicant are outside of this 1,500 foot distance from significant streams. If they're within the 1,500 feet, the significant streams are based on stream data from the US Geological Survey, and this has been augmented with data collected by Napa County Resource Conservation District. And these are being updated as additional data become available, particularly with respect to fisheries and other groundwater dependent ecosystems, aquatic and terrestrial. This map is available online for applicants to view the location of their project relative to significant streams.

A few examples of the criteria include, if you're within zero to 500 feet of significant streams, this does prompt metering and reporting as a requirement. One of the things that's across the board is any project within 1,500 feet of significant streams includes efforts to implement and enhance water conservation best management practices. Now, this is not prescriptive so much as it is a water conservation declaration form, and it is for the applicant to describe what kinds of conservation efforts are already being implemented by applicant and what other kinds of activity or activities could they add to their water conservation portfolio. And if if their project involves a newer replacement well, another requirement is looking at a 150 foot well seal depth. This is, to provide a protective measure.

The rationale behind that depth is evaluated in detail in an appendix in the technical report. We looked at various things with a local model, you know, as a prototype to look at, what if we had a seal depth of this, that, or the other depth or this, that, or the other distance from streams and looked at what would provide reasonable protection to help mitigate the influence of pumping within the vicinity of significant streams on streamflow depletion. Now, the applicant for a project could either meet the new applicable water use criterion, or they'd need to be able to demonstrate public trust considerations for their proposed project design and operation, and they'd need to be able to demonstrate reduced streamflow depletion. Through the implementation of these new protective standards, the types of project applications that may require more complex, involve time consuming, and expensive modeling effort for the tier three analysis, we hope would be reduced. And with that, I'll turn it back to Patrick.

Thank you. Okay. So I'm gonna try to summarize some of the improvements and changes that have been implemented in the 2026 WAA. Many of these kinda comport with our existing interim well standards, But let's start here. Within the tier one, with inside the sub basin, the existing water use criteria that is currently being used is 0.3 acre feet per acre.

That is changing to 0.5 acre feet per acre. And specifically in the Northeast Napa Management Area as defined by Vicky, that currently is is being the water use criterion for that area, which is in the sub basin is point three Because we're we're isolating the Northeast Napa Management Area as part of the 2026 WAA, the water use criterion is gonna maintain at that point three acre feet per acre. No net increase for new and replacement wells or existing wells with new or increases use on properties where existing uses exceed the point five acre feet per acre in the nap in the Napa Valley floor or the point three acre feet per acre in the Northeast Napa management area. Specifically, that means, if you have existing uses on your property that are extract that use groundwater and your existing uses, your existing legal uses already exceed that water use criterion, you'd be able to to maintain that extraction level, but but you wouldn't be able to increase it. Outside the outside the sub basin, for the tier one requirements, 0.3 acre feet per acre in the MST area.

That is that is consistent with our practices today. And for individual domestic well use in the MST, it's a point six acre feet per acre. This is consistent with our groundwater conservation ordinance, the chapter 13.15. And let's see here. And we also implement the no net increase policy.

So if your existing uses, your grandfathered uses that some some people call it, exceed those minimum extraction levels or those those maximum extraction levels, we would we would say that you would not be able to increase any extraction based on your existing current uses. All other areas in the county, water use based on parcel specific recharge. As Vicki mentioned, we are trying to streamline that process for our applicants by providing this this streamlined option for recharge methodology. Again, this is just a streamlined option. An applicant can absolutely ask a design professional to do a site specific recharge analysis based on site specific criterion.

For the water availability analysis, the tier two and tier three. So for the tier two, many really, the much of the changes and improvements to this document is to clarify methodologies in which to satisfy the tier two requirements for the neighboring impacts to neighboring wells. And for the tier three, applicants must demonstrate implementation of our protective standards to reduce stream flow depletion when wells are within the 1,500 feet of these significant streams as Vicki defined earlier defined earlier. Again, this is the goal of this 2026 update is to improve upon existing practices, clarify existing methodologies, and to streamline the process for our applicants and for our staff. So as I mentioned in the beginning of this presentation, these documents, the the public draft was released on March 27 for a sixty day public comment period.

That public comment period runs through May 26. We encourage our stakeholders, our community members, our design professionals to review this document, provide their feedback, and participate in this in this public process. We will also be holding a second public hearing on the WAA. This is going to be at the Napa County Planning Commission on May 6 and that will that agenda will be out later this month. We will continue to do outreach and we want to meet with our stakeholders if they have specific questions.

They can reach out to me or our natural resources division in planning building environmental services. And again, like I said, we are encouraging participation in this public comment period. That concludes Vicki and I's presentation and we welcome any questions.

Thank you. Comments from TAG members?

Just to put this a bit into context for us, could you comment on the number of applications per year? And I understand it can change from year to year, but can't What are we looking at?

10 I'm gonna hundreds. I'm gonna guess. So I'm I'm gonna guess it probably for discretionary permits, we're probably in the range of a a 100 to a couple 100. Well permitting, again, a 100 to a couple 100. So, I mean, we're we are processing a few 100 permits every year that directly relate to groundwater extraction and use. And it's it's a day it's a daily practice for our department. I'll just put it that way.

How many of those would be from, like, the Northeast Napa management area? I

would say it's it's the minority.

And do I understand correctly with the tier one, basically, it's a threshold. So you cannot get a permit if you're, I mean, if you apply for a new if you would apply for a new well above 0.5?

It's not a definite no. Really depends on existing uses on the property because we do have the no net increase kind of practice in play. And so for an undeveloped parcel that wants to build it out, develop it to its maximum but their extraction estimates exceed the water use criterion for any of the areas identified in the the WAA, we would not be able to staff wouldn't be able to support that application.

And how does it work in practice if there are no requirement for metering and reporting afterwards?

To verify if the extraction levels are maintained within the levels identified in the WAA? Yeah. So for most discretionary projects, conditions of approval will be applied to those applications for metering and monitoring and reporting to Napa County. That's the insurance we have for our discretionary actions because we can condition those. For those ministerial actions, those are gonna be mostly those individual domestic users and extraction levels for those are usually pretty nominal and de minimis. And so they'll be signing water use declarations identifying that they are to stay within this this this threshold. Monitoring for those individual domestic uses is is not gonna be a requirement, though.

Thank you.

On the recharge map, are those figures that the acre feet per acre that's figuring like an average rainfall year, am I understanding that correctly?

That's using the PRISM ten year And those are averaged over those large areas. So the site specific, you know, more highly, down to the cell detail, those are what would be provided by the county for the applicants to look more specifically at their parcel location. But it is true just even based on these aggregated, you know, estimates on the acre feet per acre on the Putty Creek Watershed where there's hard rock. Those are areas that have less recharge.

Yeah. It if I'm understanding it correctly, out on that side, you couldn't, really get a approval to pump very much out on the east side of the county based on recharge.

Right. And as I mentioned and Patrick mentioned, the applicant, if they have other site specific information, then they can do a site specific analysis.

Was there I don't know if it's in the technical document, but was there any analysis of what expectation the county has on how much water and how much pumping may be reduced by implementation of this updated WA?

I don't think we can I think it would be difficult to quantify the reduction? As you all are very familiar with with the pumping reduction work plan, the goal is 10%. If that, I I can't necessarily speak to if the the implementation of the water the groundwater conservation best practices are implied across the board if if I I couldn't quantify what that volume of water would look like though, unfortunately.

Can you describe again when like, tier three criteria would kick in?

Sure. If you have a water source, a well, a groundwater well within 1,500 feet of a defined significant stream, you would be we we would trigger the application of the tier three requirement. And so as Vicky kind of stated that 1,500 foot is kind of the the basis of the threshold. But if you get within 500 feet, there's other requirements that are gonna be implemented as part of the project.

And that would be for an existing well or just for a new well?

This would be for any new well, replacement well, intensification of groundwater extraction.

I

think that sums it

up. Okay. Yeah. So theoretically, if you have a well that is within 1,500 feet, but you're just gonna continue to use it the same way as the past, then Yeah. Unfortunately no restriction.

Yeah. Unfortunately, there's really no nexus for the planning, building, environmental services department to begin analyzing and and effectively applying requirements or conditions on on your water usage.

Okay.

For the, well seal component for these new wells within 1,500 feet or 500 feet depending on the threshold, Is that a new component or was that in the old?

That is a new provision that comes out of this draft document. Yes.

And then on the the implementation timeline, when so sixty days comment, then there's the commission the planning commission meeting and then outreach. When would this potentially go into effect?

We hope to take this to the board of supervisors for consideration early summer, July, August, let's say.

Is review of current water availability analysis on hold until this goes through or are those still being processed?

We are currently still processing applications. The 2015 water availability analysis and supplemental, the January 2024 interim well standards, they've they're continuing to to be in play until the board takes such actions to approve this new draft.

Thanks.

Okay.

We could move on to public comments. Thanks.

Matthew, you have three minutes.

Good afternoon. I assume you guys can hear me. I want to thank everyone for their time today and in explaining this. My name is Matt. I'm with EBA Engineering.

I'm a hydrogeologist and I regularly do these reports on behalf of well drillers, clients, engineering firms. So presently, at any time, I'll have a dozen of these in the works. And so I reviewed the whole package, both packages and I'll try to keep the technical questions maybe offline and in writing, just so we can have a better discussion than here. But I think administratively, Patrick, had mentioned that the existing WAAs will continue to be in play until such time as the Board of Supervisors agrees with this plan and whatever form it is. The question I'm getting from my clients are what does that mean for them, whether or not they have an existing application that's with you or they're in the process of a conditional use project or in the process of wherever they're at with respect to this WA.

So any clarification you could give us as far as if we submit a WA the day before the board approves this, are you going to run it through the old system? If you don't get a chance of reviewing it before the board approves it, what happens to that application? In other words, what is the timeline for how to process these would be very, very helpful for at least our my clients to make an understand about what they how they should proceed in the short term. And I'm assuming the well drillers have the same questions engineering firms have the same questions with how to proceed at this time in this window between April and July. So I'd appreciate any clarification you could give us with that.

I guess it's just a general comment would be a lot of this seems to be model derived, which I'm very familiar with ModFlow and its strengths and its limitations. With respect to stream flow, it looks like unless there's no wells between you and the river and there's only one well and another other considerations that if you're within 1,500 feet, yes, there may be some modeling that takes place, including for domestic users. So I'm curious if the model is available. Ultimately, if that's what everything is being built on, then if the model is available, then that would be the easiest thing to plug that in and and see what kind of stream flow you're, you know, you're coming up with. I'm a, you know, a general comment, you know, river package.

I'm not, you know, based on two stream gauges in the valley, I be a little bit concerned about that. But notwithstanding that comment, I think the major thing at this point is to just provide clarifications for our clients as moving forward as to what the process is. And then some of the technical aspects, like I said, I'll defer to written questions just for clarification purposes. And thanks again for your time and for presenting this. Appreciate it.

Thanks, Matt. Yeah,

I think for his first question about how to proceed with existing WAAs going through the process currently, I think we'll have a better understanding of the potential outcomes following the public comment period and our additional outreach to the community members. Really, I think, specifically, I think what he's speaking about is potentially the water use criterion for the Napa Valley floor, which is changing from the point three acre feet per acre to the point five acre feet per acre. That that does change kind of potential projects and especially what they're asking for. And I I I think we're gonna have a better understanding or a better process and a better explanation as we kind of progress through. And I and I hope by the May 6 planning commission, I'll I'll be able to kind of include a slide so we can kind of talk about that.

Anthony, you'll have three minutes.

Hi. Thank you for hearing me. I'm Anthony Hickey with Richard Slade and Associates. I'm a hydrogeologist working in the county on a lot of these. Thank you again for the presentation and the time today.

I will also keep it short to some high level things and then high level questions and do a little more detailed in writing. But we answered the question about the date of adoption. Just to tack on to that, at what point in the review process a project is going through review, do we will that be considered complete? Is it, you know, when when the sequel memo is complete or when you have a hearing date? Just for some clarification on when that lack of a better term drop dead date would be where we're held to earlier rules versus new rules.

And then just a couple other questions that might be able to be answered pretty easily right now. There's a change or at least a change from previous where there's a 30 degree slope previously was considered a no recharge slope and this document talks a lot about a 30% slope. Just wondered if there is any insight that could be given on that that will help our review on why that change was made and really did when looking at those recharge percentages in those watersheds that are defined on some of those maps. You know, were I think you mentioned, Vicky, that there'd be a, you know, a pixelated or we'll get the actual raster to see what those recharge percentages are. I'm curious if the watersheds were adjusted for those no recharge areas.

So will there be a pixel that says zero recharge and then everything else in that watershed, If we did a watershed wide calculation that recharge was 6%, then we go back later factor out the zero and increase the recharge percent in those areas that actually do receive recharge. You also mentioned that there was an adjustment of the BCM recharge values in the watershed that were adjusted using geology. I didn't see any discussion in the tech memo on that. Just curious if you could either point us to that discussion or give some insight on how those adjustments were made. I think that would be important for us.

And then finally, Vicki, I think you made a comment about the LSCE and MBK 2013 report. Some of those values maybe were questionable or I don't I don't wanna put words in your mouth. I don't remember the exact quote. But is that an implication that going forward that reference is superseded by the information in the technical memo provided with this WAA? I think that will be important and help us with our review as well. But thanks again for the opportunity. We really appreciate to be on the front side of this and be able to think about these things as it's being developed. It helps us a lot in dealing with our clients and, you know, moving forward. So thank you.

Any further?

Matt, you'll have three minutes.

So this is the other Matt, Matt O'Connor. And thank you for being available to make these presentations and take questions. Similar to the other commenters, I'm a hydrogeologist and have done a lot of work on WAAs in Napa County for the last ten years. And I'll have some general kind of concept comments for today. And primarily, I feel like the guidance document updates are helpful in many ways.

And yet I also feel as though the WA guidelines aren't I'm not completely comfortable that they really are appropriate as much in the sort of steeper upland bedrock dominated aquifers with a lot of topography compared to the Napa Valley groundwater basin. And I see a lot of the diagrams and conceptual things that support some of the well sealed depths and setbacks. I don't know if that modeling is all done in the context of a, you know, more or less flat lying hydrologic system or an upland system. And I guess I'm just generally concerned that the guidance may not be as appropriate in those upland areas, and I think there are a lot of circumstances that aren't taken into account. One thing in particular that I just give it as an example, I've done a lot of WAAs in upland areas and looking at the streamflow depletion issue.

And it's often the case, if not mostly the case, that the wells in question in relation to a stream, the entire wellbore is maybe 100 or 200 feet above the streambed elevation. And I'm wondering, for instance, what's the relevance of 150 foot well seal in circumstances such as that, just as an example. I'll try to provide some written comments as well. I'm sorry, one other generalization about the water availability and the sort of the Tier one conceptualization. I think I understand that the guidance is for the streamlined guidance is using the subject applicant parcel size acreage as one of the factors in the recharge rate.

And again, in these upland areas, the amount of recharge on a per acre basis for a small property is going to be pretty small. And the reality of how water flow works and how the groundwater recharge is working is that there's some upland contributing area to that point and to have a more realistic understanding of what the actual water availability would be and what the groundwater would be, we'd need to take into account a bigger area. And that's another example of I'm not so not necessarily convinced that the guidance looks at the Upland issues as closely as it might. And thank you for all the effort you've put into this. It's clear that there's been a lot of thought and careful work to try to address these very complicated issues that are very difficult to simplify and streamline.

Thanks.

We have no other callers.

Okay, that's our last item. So at this point, we could look ahead to any future agenda items that we want to flag now for future meetings. Okay, well that wraps up our meeting today. Thank you very much for the presenters. It's been really informative and helpful presentations and appreciate the public comments too which will raise some important issues.

And so with that we will adjourn the meeting and we have a special meeting I think in June. That will be our next convening. So thank you all very much for your attention and your time.