COUNTY WATER DISTRICT
409 Old Baldwin Road
Ojai, CA 93023
Phone (805)646-3403
Fax (805) 646-3860 www.vrcwd.com
Ed Lee – President
Marvin Hansen – Vice President
Eddie Ramseyer – Treasurer
Tom Jamison
Jack Curtis
Bert Rapp, P.E.
Janet Schaefer
Russell Klassen
Lindsay Nielson, ESQ
January 12, 2012
Norma Camacho, Director
Ventura County Watershed Protection District
800 S. Victoria Ave.
Ventura, CA 93009-1600
SUBJECT: COMMENTS ON THE DRAFT VENTURA RIVER
WATERSHED PROTECTION REPORT
Dear Norma;
The Ventura River County Water District respectfully submits comments to the draft Ventura River Watershed Protection Plan
Report dated December 2011. The draft report was prepared by
Cardno ENTRIX under the direction of the VCWPD.
Chapter 4 Water Demand and Water Budget
The water usage figures in this chapter are based upon the 2010 water year. While this may be close to an average year it is really irrelevant to water demand and water budgeting in the watershed because of the unique character of the Ventura River Watershed.
The aquifers are small, hold only one to three years supply of water and re-fill rapidly in one good rain year.
It would be much more realistic to utilize the 20 year design drought
Safe Yield analyses prepared by Casitas MWD because it is based upon actual ground water basin yields and user demands during droughts with variable rain years during the 20 years.
If needed the current Safe Yield analyses could be updated for recent changes in diversion restrictions and new pumping demands that may have occurred since the last update.
Chapter 8 Future Actions….
Section 8.1.4 Data Gaps recommends:

The District should convene a technical advisory group to assess and prioritize data gaps that limit development of a comprehensive water budget, with input from the Ventura
River Watershed Council.

VRCWD Comments
P a g e | 2
Our District would recommend that the greatest data gap need is not for a “comprehensive water budget” but to move forward with the Data Gaps identified in the 2001 Surface Water-Ground Water
Interaction Report referenced on page 2-42 of this report. The LARWQCB is scheduled to impose a
Pumping TMDL for the Ventura River by 2019. The most critical data gap needed for implementing a
Pumping TMDL is to fully understand the interactions between surface water, ground water and pumping. To that end we recommend changing the Section 8.1.4 bullet to read:

The District (VCWPD) should convene a technical advisory group to assess and prioritize data gaps that limit the understanding of the groundwater – surface water – ground water pumping interactions, with input from the
Ventura River Watershed Council.
Section 8.1.5 Ventura River Groundwater Management Plan
According to this report the Ventura River groundwater basins only hold a one to three year supply of water and refill with one wet year. This is in contrast to the ground water basins on the Oxnard Plain that hold a multi-year supply of water, do not recharge easily and are in overdraft. The report acknowledges that: “ground water extraction use during droughts has not exceeded recharge capability.” (Section 2.6.3.2)
In order to survive a 20-year drought the water in the ground water basins must be utilized first before water is taken from Lake Casitas. Without the water in the groundwater basins there is not enough water in the valley to survive a 20-year drought.
Therefore we do not see a need to develop a Groundwater Management Plan for the Ventura River
Watershed.
Section 8.1.6 Water Budget
The report recommends creating a watershed-wide water budget “to determine whether the water resources in the Ventura River watershed are sufficient to meet total water demand.” However Casitas
MWD already has a 20 year safe yield analysis that encompasses the lake, all ground water basins in the valley and water demand including anticipated future conservation efforts. This safe yield analysis utilizes historic and projected yields and demands. Creating a new “Water Budget” would be redundant.
If more water supply and demand precision is needed it would be better to update the Casitas 20-year
Safe Yield analyses rather than create a new Water Budget. Therefore we recommend changing the recommendation bullet under Section 8.1.6 to read:

The Casitas MWD should update the 20-year safe yield analysis for Lake
Casitas to incorporate current supply and demand projections with input from the Ventura River Watershed Council.

cc:
VRCWD Comments
P a g e | 3
Chapter 3 Section 3.4 Groundwater Management Plan
Our District does not see the need at this time for a Groundwater Budget or a Groundwater
Management Plan in this watershed. That being said we would like to comment on the recommendations for Component 11 & 12 on pages 3-22 & 3-23. These components recommend that the Watersheds Coalition of Ventura County and the Ventura River Watershed Council have administrative functions that should, in our opinion, be performed by a responsible Public Agency. The
Coalitions serve as an excellent format for gathering stakeholders and being an advisory committee but they are not an “Agency.”
The responsible Agency, if a Groundwater Management Plan is formed, should be the Watershed
Protection District or Casitas MWD.
Additional comments are included on the marked up pages of the report attached to this letter.
Very Truly Yours
VENTURA RIVER COUNTY WATER DISTRICT
Bert J. Rapp, P.E.
General Manager
Mark Horn, Senior Consultant/Water Resources, Cardno ENTRIX
Zia Hosseinipour, VCWPD