“…Although there are multiple GSAs (The Country of Fresno, 2019;Davids Engineering Inc., 2020;Dee Jaspar and Associates, Inc., et al, 2020;GEI Consultants, Inc., and Kern Groundwater Authority, 2020;Luhdorff and Scalmanini and California Department of Water Resources, 2020;San Joaquin River Exchange Contractors GSA, 2020;Semitropic Water Storage District, 2020) that specifically cite the USGS-estimated BFW (Page, 1971;Berkstresser, 1973;O'Bryan, 1992) for determination of the vertical basin boundaries (Kang et al, 2020), studies also suggest there are likely substantial volumes of fresh and usable water in groundwater aquifers not included by using the USGS-estimated BFW (Kang and Jackson, 2016). Given California Senate Bill 4 and previous research (Gillespie et al, 2017(Gillespie et al, , 2019Metzger and Landon, 2018;Stephens et al, 2019;Ball et al, 2020), one potential alternative approach is the use of the base of brackish water, where brackish water is usually defined as water with TDS concentrations <10,000 mg/L but greater than fresh water.…”