*4.4. Monitoring by Users*

The GWMPA mandates that NeDNR and NRDs jointly progress toward meeting IMP goals and objectives (§46-715(3)). NeDNR forecasts the maximum water volume from stream flow for beneficial use in both the short and long term. In the IMP, the NRD tracks yearly certification of ground water use, water well construction, and consumptive uses by municipal and non-municipal industrial water systems within its jurisdiction. It also tracks the number and location of retired irrigated acres and offsets for new uses, including depletions dating to 1997 in the over-appropriated part of the basin within its jurisdiction (§46-715(2)(e)). NeDNR tracks changes in permits for surface water (§46-716). The NRD board is elected by local ground water users.

**Mandatory IMP Interviewee #1.** "So, there is a reporting and monitoring section in the plan. So basically, the NRD and my department come together and say, "OK here are all the activities that have taken place in the last year" just in a checklist fashion, have we caused more depletions? Are there more accretions? Where are we in the permitting process? And that is telling us on an annual basis are we getting where we want to be".

The NeDNR relies on NRD records for tracking certified acres, including transfers from a water rights holder associated with retired acres and/or transferred ground water use from one tract of land to another. The NRD also uses aerial photography to insure that irrigators are staying within their certified number of acres. At the time of this study, decision-makers were finalizing plans to run an updated ground water (hydrologic) model in order to verify the number of acre feet per year that will be needed to offset depletions dating back to 1997. However, some interviewees expressed skepticism of benchmarks and incremental approaches used for monitoring and assessment of accretions or depletions under the IMP, believing that the GWMPA should require NRDs to offset depletions dating back prior to 1997, because there were prior (surface water) appropriations predating the introduction of widespread use of central pivot irrigation that were impacted by those

ground water wells. The GWMPA, however, requires only voluntary efforts to offset depletions prior to 1997 as part of an incremental approach. (§46-715(5)(d)(i)).

**Mandatory IMP Interviewee #2.** "What is fully appropriated? Is it where your development is affecting streamflow? These are measures of degree. In our mind, what is that difference? The fact that it wasn't (fully defined) when all these plans were done was disappointing, and of major concern to us. The difference between fully and over. We still don't agree with the way the department is proposing to do that. Basically, we are not really allowed to participate any more".

Those concerns were connected to perceptions that the structure of the IMP did not allow for full participation among all stakeholders, especially surface water providers, and that there were few avenues to air such grievances. Thus, perceptions of the efficacy of monitoring activities varied depending on the interests of those involved and whether those interests were represented in the development and implementation of the IMP.
