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Aubrey Rose November 8, 2024 Page 3 this sustainability goal and its long-term sustainable management of the Basin, Zone 7 has developed a series of policies, ordinances, and basin management objectives (BMOs) that together comprise a groundwater management program for the Basin. The objectives of this program are to provide for the control and conservation of waters for beneficial future uses; to promote the conjunctive use of groundwater and surface water; to facilitate the importation of additional surface water to meet Basin needs; and to use the groundwater basin to store imported surface water for subsequent recovery during drought periods. Zone 7 has set Basin Management Objectives for groundwater quality monitoring and management, including tracking and addressing any water quality degradation. These BMOs include parameters to: • Protect and enhance the quality of the groundwater, • Halt degradation from salt buildup (offset current and future salt loading), • Reduce flow of poor-quality shallow groundwater into deep aquifers, • Offset impacts of water recycling and wastewater disposal through integrated Salt Management Plan (SMP), • Recharge with relatively low total dissolved solids (TDS)/hardness imported or storm/local surface water, • Manage quality on a regional basis as measured at municipal wells (such as those operated by both the retail water agencies and Zone 7); • Minimize threats of groundwater pollution through groundwater protection. The sustainable management criteria in that GSP, including criteria for water quality, are essential to ensuring the long-term sustainable management of the groundwater basin, for the benefit of all users in the County. The DEIR does not meaningfully engage with the standards set by the GSP, nor does it analyze the reasonably foreseeable impacts to water quality that may occur as a result of the Project’s implementation. Zone 7 manages and treats groundwater to meet current and established pending future regulatory requirements for drinking water supply and plans to be in compliance with future water quality standards. To assist Zone 7 in meeting this duty effectively, it is important that proposed projects accurately disclose and evaluate that project’s impact on the BMOs, and identify effective mitigation strategies where the Project’s may result in exceedances of the GSP sustainability criteria. Because the DEIR does not engage in this analysis, it fails to adequately inform the public about the potential impacts of the Project, and risks advancing a project for approval that may impose unanticipated impacts and costs on the Basin. The DEIR does not include sufficient analysis to determine whether the Project will comply with the water quality standards in the GSP. The DEIR concludes that the Project “would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality,” and that therefore any impacts to water quality are not significant. (Impact HYD-1). As to groundwater, the DEIR provides a circular reasoning for this conclusion: