Category: Planning

LADWP’s Paper Water Leverages on MWD Supplies

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When the LADWP uses paper water, not only does it affect Los Angeles residents, it also impacts utilities and residents outside of the city. 'Paper water' is water that “utilities claim they have access to, but is difficult or impossible to access for various reasons”.

When the LADWP claims to have access to more city owned domestic water than it really has access to, that allows the department to understate how much water it needs from the Metropolitan Water District.   

MWD Makes up for LADWP Paper Water

Using paper water to prop up the perception of its domestic supply, the 2000 UWMP* suggested that the LADWP would only need to purchase and additional 3.53 million acre-feet of water between 2000 and 2015.

However the department was unable to follow through on its claims. Only 4 times in 16 years did the department meet its own projections. Over the other years it had to purchase 47% more water from the MWD amounting to 5.20 million acre-feet at a greater unit cost. 

This is one of the ways that the department hides the water shortage in the EIR's that work their way through the planning process to shield development.

Obviously this practice would impact the MWD's operations to store surplus water as a hedge against drought in its Diamond Valley Reservoir and at Lake Mead.

*I used the 2000 UWMP because it presented a larger sample size of MWD purchases than later plans would. Later UWMP's use paper water similarly.  

First Looks: The LADWP 2015 Draft UWMP – Hiding the Shortage

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After spending a few weeks paging through the just released LADWP 2015 Draft Urban Water Management Plan, my immediate conclusion is that the plan is a thinly disguised effort to hide the city’s low water supply levels from the planning process to protect development.

This draft, like past UWMP’s, continues to project levels of water in all supply categories that the department does not have access to and it continues to assert access to water in categories that aren’t really a supply such as Conservation and Harvesting.

California law requires that utilities update the UWMP every five years to demonstrate long term water supply availability before approving new projects. This task has become tougher to prove as the regions grow and various interests throughout the state assert their rights to the state’s water supply. The department compounds the problem even further when it reports to planners and developers that there is sufficient water for growth despite the shortage.

In 2010 the LADWP found that totaling up aqueduct, groundwater, recycled water and MWD water was no longer adding up to the total supplies it needed to show as evidence of sufficient growth. To solve this problem, it began to look for new ways to produce water. Some categories were real such as stormwater capture and indirect potable reuse but other categories were simply fuzzy water meant to artificially raise the total supply using paper water.

A Line-by-Line look at the Future Water Supply Projections

The following is a line by line look at the supply projections in the draft's Service Area Reliability Assessments table. I’ll show where the real water is and what’s vulnerable to challenge.

Conservation

I’m going to be blunt. Conservation is not a supply. Conservation should be used to lower the baseline demand and from there, the department should demonstrate how it will meet that. However, the department uses Conservation as a supply to merely to bump up the total supply figures shown in the Service Area Reliability Assessment tables to present a UWMP that's favorable to planning documents.

conserv

 

The department’s 2015 draft shows Conservation as an existing or planned supply that will contribute up to 125,800 Af/y to the city’s water portfolio. But simply put, this is ‘paper water’.  This is done to hide a portion of the total shortfall the department doesn’t want seen in Environmental Impact Reports that are attached to projects for review by the planning department.

There is a simple test to see if Conservation (or any other category of water) is real water or imaginary water. The 2009 California Water Plan Update describes ‘paper water’ as water that “utilities claim they have access to, but is difficult or impossible to access for various reasons”. 

Using that definition in our test, if we eliminate all of the city’s real incoming sources of water such as the aqueduct, groundwater, recycled water, stormwater, and MWD water, and leave the city with only Conservation, how much water would the city have access to and available to use?

None. The leftover 125,800 AF of 'water' the LADWP claims it has access to is not accessible.  You can’t wash your hands with this water and you cannot sip it from a glass. Consequently, it's paper water and not a supply.

2015CSVPaperAsserting that ‘Conservation’ is a water supply allows the department to manipulate the UWMP's supply projections, making it appear that the city’s total available supply will be 611,800 Af/y in 2020 and grow as high as 675,700 Af/y by the year 2040.

However, when we remove this imaginary water from the table, the departments total projections fall to a dismal 536,370 Af/y and over time it grows to just 600,770 AF/y by 2040. This is would fall more in line with the city’s historical supply.

I’m sure the department sees another benefit to asserting that Conservation is a supply. It doesn’t have to report the actual results like it does with real water from the aqueduct, groundwater, MWD, and recycled water which are all measured as they enter the water system.

Putting Conservation on the supply side of the equation creates a fuzzy math scenario of future water supply that does not belong in documents that rely on the UWMP. The department is basically saying, ‘IF the public reduces it gallons per capita daily by 50%, that’s like increasing the supply to 638,235 AF/y’ or ‘IF the public could meet 100% of the city’s projected conservation level, that would be the same as reaching 675,100 AF/y.

Prior to 2010, the city had always deducted conservation savings from the baseline demand side and calculated the required supply from there. If it did this here, the projections would be in the range of 536,370 to 600,770 AF/y. The department would then have to provide a plan to explain how it will get the city to reduce its per capita supply from 130 gallons per day to just 95 gallons per day.

Aqueduct

aque

 

The next supply item in the planned supply table is the Los Angeles Aqueduct. Sadly, the LADWP no longer finds William Mulholland’s engineering marvel worthy of top billing anymore. Instead it appears that the department wants optics on something called ‘Conservation’ in the UWMP even though that’s not real water like the aqueduct. It’s important to note that the Los Angeles Aqueduct continues to be the city’s largest owned producer of water in the city’s supply portfolio.

2015AquPaper2007This item in the Draft 2015 UWMP uses paper water in the Los Angeles Aqueduct projections to hide 68,030 to 85,730 AF/y of the city’s total supply shortage.

The draft does this by seriously over estimating how much water is available through the aqueduct.

It’s nothing new however. The departments past UWMP’s had projected upwards of 380,000 acre feet of water per year entering the system. This draft cites up to 293,400 Af/y is still far more than the aqueduct’s actual average supply of just 207,670 AF/y between 2007 and 2012.  (To be fair, I’ve purposely excluded the last three years due to the recent drought.)

There is no reason to believe that future aqueduct supplies will average higher than 227,000 Af/y even if the department is able to lower the amount of water needed to mitigate Owens Basin dust levels.

Groundwater

ground

 

The next major source of water supply and third on the list is Groundwater. Like every UWMP before it, the Draft 2015 UWMP continues citing far more access to groundwater than the department really has access to.

2015GWPaperThis conclusion is made by comparing the actual measured groundwater supply that has averaged just 74,390 AF/y between 2000 and 2015 with the departments Draft 2015 UWMP projections of 112,670 to 114,070 AF/y. Anything more than 74,390 AF/y is paper water which is used to bump up the total supply and hide the departments shortage in planning documents.

From a historical perspective, there is simply no evidence that the department will meet the projections they cite in the current draft. Claims of over 100,000 AF/y have been made in every iteration of the departments UWMP since 1985.

Recycled Water – Irrigation and Industrial

Recycled water is next in the planned supply table in the Draft 2015 UWMP. The department split Recycled water is split between two sub categories back in 2010 and that continues today. They are ‘Irrigation and Industrial Use’ and ‘Groundwater Replenishment’.


Irr

 

Irrigation and Industrial Use, better known as purple pipe is expected to contribute 19,800 AF/y of water into the city water system by 2020 and increase to 45,400 AF/y by 2040. 2015RCYPaperHowever, the departments history of meeting purple pipe projections suggests that they will not come close to meeting these new projections either. Over the last eight years the department’s average has been just ~7,500 AF/y.

EIR’s produced between 2010 and 2015 have all claimed that by 2015, water recycled and distributed through purple pipe would be contributing 20,000 Af/y into the city’s water system.

However, the department missed that mark badly with only ~9,800 AF of measured supply by September of 2015.  Earlier UWMP’s promised even more water, citing that up to 29,000 AF/y would have been available by 2015.

Even given the chance that the LADWP might eke out at least 15,000 AF/y of purple pipe water, the Draft 2015 UWMP is effectively be hiding up to 30,400 AF/y of the city’s total supply shortage using paper water in this particular category.

Recycled Water – Groundwater ReplenishmentRepl

 

Our fifth line of the planned supply table is Groundwater Replenishment. This is not expected to begin contributing the city’s water portfolio until 2025. Groundwater Replenishment is a treated wastewater program known as Indirect Potable Reuse which is similar to Orange County’s successful IPR program.

If the department is successful at rolling out IPR, this may turn out to be a real supply. How much we actually see entering the system on a year to year basis remains to be seen.

Stormwater Capture – Harvesting

What was new to the 2010 UWMP but considered only a ‘potential supply’, Stormwater Capture has been undeservingly upgraded to a ‘planned supply’. It is split between two line items, Stormwater ‘Reuse’ and Stormwater ‘Recharge’.

harvest

 

Stormwater Reused is the sixth supply line item in the planned supply table. Also known as Capture and Reuse or Harvesting, it is another fuzzy water category consisting of Rain Barrels and Cisterns. The department claims that these components will be contributing to 400 AF/y to the city’s water system by 2020 and that will increase to 2,000 AF/y by 2040.

In the previous 6 years, the 2010 UWMP asserted that Harvesting would contribute 2,000 to 10,000 AF/y of water into the city’s water supply portfolio but none of that was ever reported.

Development projects throughout the city parroted that claim in their EIR’s but the department could never measure it nor report it.

Whether it’s the 2010 UWMP or the 2015 plan, this category fits the definition of paper water because the department has no direct access to it.

Rain barrels and cisterns are back yard, privately owned containers that do not have gages mounted to them that report back to the utility. There is no way the LADWP can tell if they are actually in use, whether they’ve collected rainwater or if they have been repurposed for other uses. I get the sense that they are keeping this category around mainly so that they can give away rain barrels to promote the conservation.  

The Draft 2015 UWMP uses paper water in the Stormwater Reuse category to hide 400 to 2,000 AF/y of the city’s total supply shortage.

(Correction: The graph and analysis in this section incorrectly cited the Single Dry Year table of 100 to 400 AF/y when Average Year Table was meant to be used.  The level of paper water in this section was raised to 400 to 2,000 AF/y - 3/3/2016 dcoffin) 

Stormwater Capture - Recharge

recharg

The seventh line item of the UWMP planned supply table is ‘Recharge’.  Over the years the city has relied on ‘natural recharge’ but this has severely decreased due to the city’s urbanization because as structures and roads were built over permeable soil.

The intent is to build an infrastructure that will capture up to 15,000 AF/y of water during intense rainwater events and allow it to infiltrate into to the ground much like natural recharge.

This may very well be another form of supply that is difficult to access given that is relies on rain events. For example, El Nino was thought that it would bring heavy rains to the Los Angeles area in the Winter/Spring of 2016 but that did not happen.

Recharge will be subject to the same meteorological events that groundwater pumping relies on and as noted earlier, groundwater pumping has never met the long term projections found in past UWMPs.  There is no guarantee that it will result in 15,000 Af/y supply until the program is in fully implemented and effects can be measured as it enters the city’s water system.  How much we actually see entering the system on a year to year basis remains to be seen.

MWD Water Purchases with Existing/Planned Supplies
MWD

 

‘MWD Water Purchases’ is an interesting category because the department has consistently ‘underestimated’ how much it will buy from the Metropolitan Water District.  This happens because as previously noted, the LADWP claims it has access to water it doesn’t have access to.  Sooner or later the department has to quietly make adjustments and purchase additional water from the MWD to make up for the shortage.

The 2015 projections are pretty stunning given that it represents a 68% drop from the 2010 UWMP and worse, an 80% drop from the real purchases. 

Given how much paper water is in this draft UWMP which includes the so-called ‘Conservation’, there is no evidence that the LADWP will be able to meet those projections and subsequently limit MWD purchases at this level unless Mayor Garcetti wants to deliberately deepen the city’s water supply shortage by plunging the city into a Phase IV or Phase V restrictions.   

Between 2000 to 2010, the LADWP projected it would be purchasing an average of 247,995 AF/y from the MWD. But during this time the actual average supply it purchased from the MWD during that time was 30% higher at 325,570 AF/y.

This clearly demonstrates that the LADWP has not been meeting its real water projections and that its projections are indeed full of paper water. The department’s MWD projections are simply not reliable.

Transfers

transfers

 

Over the last six years, projects working their way through the planning process cited in their EIR’s that 40,000 AF/y of Transfer water would be available to the city by 2015 along with other surplus water in the other categories. However, the department was not able to access this water that so we can firmly place this in the category of paper water.

With the water market turning increasingly bleak, the LADWP rightfully did not include Transfers in the Service Area Reliability Assessments table as a ‘Planned Supply’.  Instead it downgraded Transfers to a ‘Potential Supply’ but it still remains on the Service Area Reliability Assessments table making it ‘appear’ as if it is accessible.  

The chances that the department will have access to this water is fairly remote given that there no willing sellers in the Central Valley or Northern California and its like that the department would find itself bidding against the well-financed Metropolitan Water District.  

The $40 million spent by the LADWP on the Neenach Pumping Station Turnout Facility Project in the Antelope Valley doesn’t seem like a great investment today.

MWD Water Purchases with Existing/Planned Supplies and Transfers

MWDpotential

 

 

The tenth and last item in the Draft 2015 UWMP Services Area Reliability Assessment is an alternative MWD Water Purchase should the LADWP be able to secure contracts for water in the ‘Transfer’ category.  It states that if the LADWP were to be able to secure contracts for 40,000 AF/y of Transfer water, this would result in lower MWD purchases amounting to ~20,630 to 35,430 AF/y.

 

 

Show Me the Water‘s Failed Promise – The Newport Banning Ranch File

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It’s bad enough that water utilities project far more supplies than they have access to which by definition is paper water. It's bad enough that using this imaginary water they always come to conclusion that every project requesting a WSA has sufficient water to proceed. But recently it became clear to me that are other forms of paper water that comes in large amounts as well. Paper water by definition is water the city says it has available to it, but it can never access because it’s being used by someone else within the state's water system.

nbr2In July I was asked by the Banning Ranch Conservancy to look at the Newport Banning Ranch water supply assessment as they prepared for a California Coastal Commission meeting on the project. Having reviewed quite a number of Los Angeles Department of Water and Power water supply assessments I knew the first place to look for paper water would be in found in the utilities projections. Over time I've suspected there were other areas where paper water could be found but L.A.’s sheer size made it difficult for me to validate those.

Reviewing this projects WSA was a good opportunity for me because it is more typical of WSA’s that are produced throughout Southern California and the city’s relatively small population also made it easier to see whether housing growth can contribute to paper water ‘surpluses’ under SB 610.

For a little background, the Newport Banning Ranch (NBR) project is a proposed 1,375 housing unit development in the City of Newport Beach that also includes commercial. The city’s water supply is quite a different from the City of Los Angeles's water supply in that groundwater clearly is a substantial portion of the city's water supply. Newport Beach does not have its own domestic ground water supply underfoot but instead it has four wells that are located are located about five miles away in Fountain Valley which are managed by the Orange County Water District. When ground water is in short supply the city buys imported water from MWDOC.

When I dug into the Newport Banning Ranch WSA I found it was similar to the water supply assessments that are routinely produced by the LADWP. The Newport Beach water supply assessment relies heavily on 'paper water' to create a façade of surplus water just like L.A.'s water supply assessments. When reviewing the city’s sources of water supply, I found that they never met their respective supply projections and there was no chance that they ever would. 21 percent of the city’s projected water supply was water that the city didn't have access to. Hence it was ‘paper water.’

Growth’s Contribution to Paper Water

But there was more. What about housing that doesn’t trigger SB 610 requirements for a WSA? Failing to report cumulative housing construction would be another form of paper water. If a WSA doesn’t acknowledge that new housing has been constructed since the city’s Urban Water Management Plan was approved, the water demand from the unrecognized housing would be viewed as a unused water that is still available for new projects.

NBR2The Newport Banning Ranch water supply assessment was based on an increase of just 1,039 housing units over 20 years. That figure came from the city’s Urban Water Management Plan which in turn comes from the RHNA allocations that are imposed on cities. A subject that I’ve written about extensively here.

Right off the top, the NBR project's proposed 1,375 units exceeds the city’s 20-year water plan by 336 units meaning that new water supplies should have been identified in the WSA.

But that led me to the next question. Aside from the fact that the project is larger the city’s projected housing growth, how many units were built in the city since 2005 that did not trigger a water supply assessment? The answer was stunning.

In just five years the city’s rise in housing exceeded the UWMP's 20-year projected growth by 380% or 5,017 units and there was still fifteen years to go. The extent of this growth really surprised me. I didn't expect that growth could be so under-projected in a UWMP that it would decidedly tip the scale towards insufficient supplies in just five years. Shouldn't a water supply assessment capture this demand on water supply? I think so. You can't say your Showing Me the Water if your not disclosing the demand.

Not surprisingly, the water supply assessment didn’t acknowledge this new housing so this water could be viewed as an unused surplus. The project's WSA simply ignored the new housing. Had it acknowledged that the city had grown, it may have created pressure on the developer to find new water supplies. The Show Me the Water Law is supposed to link large projects to water supply. It should also assure that large projects are not be claiming to have access to water already that has already been committed elsewhere.

SB 610’s silence on projects that are less than 500 units effectively guts the law. The law only says that a WSA must include a ‘discussion’ of various elements of the water supply such as total projected supply during normal and dry years. The law doesn’t explicitly point out that the discussion should include housing growth that was not accounted for in the UWMP. Another weakness in the law is that it doesn’t have any regulatory oversight. This leaves it up to citizens to have to challenge water supply as it appears in an EIR.

The law should be expanded to require cities to keep a running total of new demand for recently approved projects that do not trigger a water supply assessment and incorporate that into all EIR’s. And while its keeping a running total of demand, it should also inform citizens on what that increasing demand will do to their monthly water allocations and rates.  

This would give decision makers a little more information that might help eliminate any water shortage surprises should the increase in projected housing exceed the projected increase in the UWMP.

NBR’s other Imaginary Water

NBR1Aside from the WSA’s failure to mention new water demand from the city's ongoing housing construction, there were other problems with the Newport Banning Ranch WSA.

The WSA suggested that the city’s water supply would increase from 18,648 AF a year to 21,716 AF/y. This suggestion would lead the city's decision makers to incorrectly believe that supplies are increasing which would be sufficient for the projects proposed new housing. However a review of the city’s historical supply tells us another story. That there's little chance that the city's future supply will ever exceed 17,200 AF year-after-year or that it will ever see supplies exceed 19,000 Af in any one year.

What I found was that the total well water supply was not enough to meet the UWMP projected supply. Since 1990, OCWD groundwater allocations have been averaging about 72 percent. In the last 10 years that figure has dropped to 62%.

The WSA also suggested that during droughts when wells weren't producing sufficient supplies, the city would be able to make up for those shortages by purchasing imported water from MWDOC. The WSA even goes so far to state that MWDOC "was able to show that it can maintain 100% reliability in meeting direct consumptive demand under condition that represent normal, single driest, and multi dry years through 2030". However, the fact is that MWDOC doesn’t have enough water available for purchase to meet the city’s 21 percent shortfall even in wet years which is shown by the gap in the chart at the right labeled 'paper water'.

All Claims of Sufficient Water Supply Should Be Considered Suspect

The Newport Beach WSA isn't unusual. I suspect it's typical of water supply assessments produced throughout Southern California and maybe even Central California as well. The ‘Show Me The Water’ law requires that a water supply assessment be attached to the projects EIR when the project is 500 units or larger. While small and medium size projects do not require a water supply assessment, CEQA still has a requirement for an analysis on water supply in the Utilities section of the EIR.

The EIR merely has to refer to the local utilities UWMP to serve as an assessment for these projects. Whether the discussion of water supply is found in the WSA or the UWMP, there is a nearly 100 percent chance that the utilities water supply includes a substantial amount of paper water. All claims of ‘sufficient’ or ‘adequate’ water supply should be reviewed closely.

How Much Paper Water Costs

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WSACoverCan you buy paper water? Absolutely.

Today the LADWP sent out an agenda for an upcoming meeting of the LADWP Board of Commissioners.  One of the agenda items on it was the NoHo West project Water Supply Assessment with a recommendation by LADWP Water Systems section for the Board to approve it. Like other WSA's this one is no different. The requirement for a water supply assessment comes from the California's 'Show Me the Water' legislation. This WSA like the other LADWP water supply assessments fails to do that.

Most urban water agencies like the LADWP have upended SB-610 and turned it into a pay to play permit that offers paper water to help approve projects for a fee. For $17,000 the department will produce a report full of Imaginary Water that will get your project approved. 

At that price you should expect a very elaborate highly detailed report but in reality the LADWP provides a little more than 20 pages of analysis along with 160 pages of poorly rendered photocopies that have little relevance to the projects analysis except for what the city Planning department provides. That comes out to about $800 a page. The rest of the report is primarily a crude cut and paste job that offers no extra insight to the water supply for decision makers to base their decision on.

If we break down the NoHo West WSA into simple little segments it goes like this:

The first 21 pages of the WSA goes on to describe the 742 unit project that's also full of retail and office space. It estimates how much water demand the project will impose on the city and it feigns on how much the extra conservation the LADWP was able to negotiate out of the developer to reduce demand. Not surprisingly it ends with a conclusion that this projects 298 Af/y is accounted for in the City's 2010 Urban Water Management Plan even though its not. This is essentially where the analysis ends.

At page 22 the department inserts twenty pages of stale, highly inaccurate supply projections into the report and goes on to describe the city's water supply infrastructure, environmental constraints and conservation measures. All of this information is already available in the City's UWMP.  

At page 51 the department inserts a letter from the City Planning Department that makes the request for the WSA. The Planning Department letter actually has more original material in the WSA than what LADWP contributes for its part.

At page 67 the department then inserts a few letters from the developers agent describing the various proposed alternatives for the project are inserted into the WSA.

$17,000 would seem to be an outrageous amount of money if it just ended there. So here the LADWP stuffs in a bunch of over copied, poorly rendered filler that adds little value to fatten up the report another 101 pages. None of this extra information provides anything useful for assessing whether the project might be an undue burden to the city's residents or if there really is sufficient water supply. In fact it may be a distraction meant to discourage the reader from seriously reading it and asking further questions during the approval process.

In this section we find what might be the most copied court judgement ever, the City's groundwater adjudication which claims what rights the city has to San Fernando Groundwater Basin. This document has little relevance to the NoHo West project. Its presence serves to give the reader the impression that the department has its act together even though it failed miserably in delivering what groundwater it claims it has to the city residents.

Then we get to page 88 for the obligatory piece of CA water code that requires retail water agencies like the LADWP to produce a water supply assessment for projects that are 500 units or larger just in case those projects are not accounted for in the city's UWMP. Despite the legislations name however, the LADWP doesn't really show us or the Board of Commissioners any water. Just paper water.

Then we get to the biggest chunk of this cut and paste job because the report is still pretty thin. The Metropolitan Water District should get royalties on these 86 pages each time it shows up in a WSA. Oddly, this half of the WSA's 180 pages comes from the very agency the City says it doesn't need much anymore and it's going cut 50% of its purchases from. The MWD contribution is guaranteed to put any bureaucrat asleep since it's mostly devoted to bond money and negotiations with other water agencies to keep our reservoirs full. They are full aren't they?  

Despite the $17,000 price tag, it's money well spent for the projects developer. Even after two and a half decades of falling water supplies and emergency drought ordinances, that $17,000 buys them confidence that the LADWP will identify just enough paper water to usher their project through.  How good is that!

 

L.A. City Prodded to Grow Without Additional Water

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In the most recent Water Board Water Conservation Report showing the state's June 2015 conservation, LADWP has been revising population figures presumably to keep the Residential gallons per capita daily (R-GPCD) level from getting out of control. They are now estimating monthly population growth and using each months figures to calculate residential water use.

I was surprised they kept using the 3,935,257 figure from month to month since leaving the population number where it was would have artificially raised the R-GPCD while population and demand increased.  The screen shot from the report shows the department's estimates that the city  has grown by 55,089 residents in last twelve months (or roughly 19,674 new units1 constructed) while it has been losing water supply.

ladwpPop

RHNA forces cities to identify properties that are suitable for development for the number of units they are allocated for. Despite the 7 year long water deficit the city has been fighting, the increasing population numbers that the LADWP is providing is a result of the California's RHNA requirement. If a developer wants to build on a property identified in the Housing Element (a RHNA requirement), the city can't say no by state law unless the UWMP or WSA is successfully challenged.

Any gains being made by residents to recover from the drought (turf removal, limiting landscaping watering days, low flow toilets, high efficiency washers, etc.) to increase storage levels and reserves are simply wiped out the state and city planning process.

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1 2013-2021 Los Angeles Housing Element reports average of 2.8 inhabitants per dwelling unit.

Running 9 Cities Out of Water

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In a recent article I wrote that California's biggest danger to water reliability isn't the lack of dams or groundwater, it was the State's growth policy that's forces city's to build. In its drive to produce housing to meet a desktop analysis that says the state will grow to ~51 million people, the state uses a little known legislative law called RHNA that 'tells cities' throughout the state how many units they must provide for. The cities must then answer in response by identifying properties (and even re-zone to allow for higher densities) where developers can build those units if the properties become available on the market.

Recently a news article listed Nine California cities running out of water. Most of them are in the central valley where it is especially bad. To emphasis how disconnected the State's RHNA process to the water challenges that cities face, I've provided is a list of those nine cities along with the number of units each city's is allocated to provide for and a rough estimate1 on how much water will be needed to support those units should they be built out.

rhna1

On one hand each of theses cities are confronted with a huge water deficit resulting in an unreliable water supply and on the other hand the State is pushing them to increase housing in places where its no longer practical. Literally RHNA is running cities out of water. The housing allocations are running up water demand to the point where cities have insufficient supplies.

Between the 2006/2013 and 2014/2021 RHNA allocations, the City of Los Angeles has had to identify properties that could be developed for 194,000 units.

Updated 7/31/15

In the most recent Water Board Water Conservation Report, LADWP has been revising population figures presumably to keep the Residential-GPCD level from getting out of control. They are now projecting monthly population growth and using each months figures to calculate residential water use.  The screen shot from the report shows the city has projected that it has grown by 55,089 residents while the water supply has dropped.

ladwpPop

RHNA forces cities to identify properties that are suitable for development for the number of units they are allocated for. Despite the 7 year long water deficit the city has been fighting, the increasing population numbers that the LADWP is providing is a result of the California's RHNA requirement. If a developer want to build on a property identified in the Housing Element (a RHNA requirement), the city can't say no.

 

1RGPCD data in the May '15 Urban Water Supplier Report was used as a basis for each cities demand.

The WSA – Bringing Imaginary Water to L.A.’s Big Projects

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In a previous article I wrote that The Los Angeles Department of Water and Power was confronted with two conflicting demands that dates back to 1990. The department’s conflict is between providing enough water to city residents from a rapidly shrinking water supply that once averaged 680,000 Af/y and is now just over 610,000 Af/y and then also show evidence that the city’s water supply is growing to assure continued growth. 

By now most of the public is well aware that there is a water shortage and that the DWP has been furiously trying to reduce the city’s residential per capita consumption by bombarding the media with accounts of shortages, imposing emergency drought restrictions, ‘drought shaming’ residents into using as little water as possible, and even paying them to tear out lawns and substitute it with drought resistant landscaping.

What the public is not aware of is that the LADWP puts on a very different face when it comes to assessing demand and assuring water supply for large new projects that consume the equivalent of 500 units or more in its Water Supply Assessments also known as WSA’s. Performing a water supply assessment is required by state law for very large projects and the department has produced more than seventy of them since 2005.

You need water? We got the water! Step Right in line.

1444 unit SOLA Village ProjectThe DWP’s water assessments are akin to a Hollywood movie set whose front facing facades of old western towns look like the real thing but when you step through a door all you find is an empty lot.

Read through a WSA and you’ll be transported into a parallel world where there’s plenty of surplus water to support a projects demand for the next twenty years along with all the other planned future demand that don’t trigger water supply assessments. But look behind the report at the actual supply figures and you’ll find that like the old western town on the big screen, the WSA is a mere facade as well.

Let’s take a recent example of the large 1,444 unit downtown SOLA Village project that the LADWP recently recommended to the Board or Water and Power for approval. Keeping in mind that the City of Los Angeles is already reeling from a water shortage and has been since 1990, the DWP’s Water Resources Section concluded in the projects water supply assessment that “adequate water supplies will be available to meet the total additional water demand” and that the demand “can be met during normal, single-dry, and multi-dry water years” for the next 20 years!

The department came to this conclusion by citing water demand and supply forecasts from its own current Urban Water Management Plan. A practice that is allowed by the state but should bring to question the sincerity to the laws “Show Me the Water” hype.

unmetRCYThe city’s past water plans have always claimed to have access to amazing amounts of water but in reality its water that can never be delivered or touched. You’ll never be able to wash your hands with it or sip it from a glass. Its imaginary water destined only for the pages of WSA's and UWMP's that are used to approve projects by decision makers.

For instance, supporting the SOLA Village project, the WSA cites that over the next twenty years the department will be able to build up recycled water supplies “eight-fold” to an amazing 59,000 Af/y by 2035. The problem however is that they’ve made similar claims to this in every preceding water plan going back to 1990!

The 2010 and 2005 plans that are routinely cited in the city's WSA’s both stated that we would be enjoying 20,000 Af/y of recycled water by 2015! In reality though, we’ve only seen an average of 7,392 Af/y since 2005 and we missed the 2015 target by 13,000 AF or 4.2 billion gallons.

Touching on another source of water, the SOLA Village WSA goes on to claim that stormwater capture will increase the water supply by 25,000 AF. Stormwater capture while not new, has been getting a lot of press attention lately when it was singled out by the city as a promising groundwater recharge component that would increase supplies.

But stormwater capture along with groundwater is highly speculative and certainly not sustainable on a year-to-year basis given the whims of Mother Nature. We can only look at averages and the averages have never been good to WSA’s when you look at them historically.

Certainly the city could bump up groundwater recharge with larger catch basins but rain barrels? Seriously? The departments WSA suggests that 10,000 Af of the 25,000 AF total would be met by rain barrels and cisterns. It would take 65 million of those plastic 50 gallon barrels that cost residents about $100 to buy. I suspect that the DWP is perhaps leaning towards underground cisterns to capture some of that water. But how would we know? WSA doesn’t positively identify how many or where these cisterns will be located. It just throws out the claim. WSA’s are supposed to “Show Me the Water” as the law was named, not make empty promises.

unmetGWContinuing on empty promises, groundwater has always been the department’s go-to resource when you need to bump up imaginary water. The SOLA Village WSA benefits in this trend by citing wild groundwater claims that states the department will be able to deliver more than 100,000 AF year-after-year. However, so did literally every plan before it.

Since 1990 the DWP’s Water Systems Section has repeatedly claimed the city would be receiving an average of 100,000 AF or more each year but that was never met. The WSA doesn’t tell you that. The city’s average yield has been just 67,000 Af since 2000. The WSA also doesn’t tell you that. It doesn’t tell you that only three times since 1990 has it ever exceeded 100,000 AF. It doesn’t really tell you we really don’t have enough water for these projects.

Susceptible to Challenge                                                              

Given the way the department carelessly cites access to large sums of unobtainable water to shore up evidence of sufficient supply, this makes WSA susceptible to challenge. WSA’s are a requirement of SB 610 and SB 221 which are collectively known as the “Show Me the Water Laws” but  LADWP’s WSA’s plans have not done that since 1990.

California’s Challenge to Reliable Water isn’t Infrastructure. It’s RHNA

Published / by dcoffin / 6 Comments on California’s Challenge to Reliable Water isn’t Infrastructure. It’s RHNA

The state’s biggest challenge in meeting the population’s water supply requirements isn’t conservation, it isn’t lack of infrastructure, not storage, and not groundwater. It’s RHNA, a little known wonkish piece of legislation embodied in Government Code 65580 that's mostly known to planners, developers and city hall staffers. 

What follows might sound like we’re veering away from the focus of this blog but stick with it, RHNA affects water demand (and electric power and traffic) in a very heavy handed, mindless way. You’ll see why.

State Level RHNA

RHNA (Regional Housing Needs Assessment) is a law that requires the state Department of Housing and Community Development (HCD) to establish the region’s existing and projected housing needs. RHNA prods and some might say it threatens cities into produce housing and while it presses for growth, nowhere in the state level is there an evaluation as to whether the water supply is available.

The RHNA process starts out with population projections generated by the state’s Department of Finance (DOF). These population figures are then sent to HCD which takes this data and develops regional housing (RHNA) allocations. The allocations, spread out evenly between Northern and Southern California, are distributed among 38 regional planning agencies through a RHNA Determination Letter.

Regional Level RHNA

Every region in the state has a planning agency that assigns housing allocations to the cities and communities they oversee. When regional planning agencies receive the Determination Letter, they take the regional RHNA allocations in it and break it down to city level RHNA allocations. When the HCD sent Southern California its Determination Letter showing RHNA allocations (pdf), the Southern California Association of Governments (SCAG) w­­­as assigned to provide between 409,060 and 438,030 housing units to be spread out among its 191 cities inside Los Angeles, Orange, Riverside, San Bernardino, Imperial and Ventura counties. The planning agency that represents San Diego (SANDAG) was assigned to provide 161,980 units.

To name a few other regions, if you live in Fresno its planning agency (FCOG) was assigned a RHNA allocation of 41,470 housing units. Kern’s planning agency (KCOG) was assigned a RHNA allocation of 67,675 housing units and the San Francisco Bay Area agency (ABAG) was allocated to provide for 187,990 new units. Regional planning agencies simply accept the HCD numbers at face value.

This step in the RHNA process tends to get a little ugly. Using a number of factors such as jobs, density, transportation, income levels, developable land, the regional planning agencies divide up their regional allocations into city level RHNA allocations (pdf). The regional planning agencies do not evaluate whether there is a sufficient water supply available to support housing requirements when they impose the allocations on the cities or communities. This is where the disconnect, intentional or not begins.

Some cities like Los Angeles accept these housing allocations with reckless abandon and run with it while other cities like Irvine, Palmdale, La Mirada and Pleasanton have tried unsuccessfully to challenge the regional agencies role and RHNA allocations in courts. In Irvine, the city had designated a decommissioned naval base to be the site of the “Orange County Great Park’. However, SCAG saw its potential as a huge housing development and applied a RHNA allocation of 35,660 units to the city. Pleasanton sought to limit growth with caps that were approved by voters but was sued because their housing plan they did not comply with RHNA.

City Level RHNA

The next and final step in the RHNA process is at the city level. Each city after having received their share of RHNA allocations must now incorporate it into a housing plan called the ‘Housing Element’. The Housing Element identifies the locations of all the parcels in the city that are candidates for higher density growth and is one of the eleven 'elements' that goes into a city's 'General Plan'. This is effectively the only place throughout the RHNA process where water supply comes into play, albeit indirectly.

The Housing Element does not evaluate whether there is a sufficient water supply available to support housing requirements. Instead it leaves it up to the water agencies UWMP. In the City of Los Angeles’s Housing Element, it has a section on ‘infrastructure’ where water supply is brought up. Here, the plan cites the 2010 UWMP stating “there is an adequate supply of water to serve the population growth projected through the year 2030, beyond the Housing Element planning period.

Clearly the adequacy of the water supply in Los Angeles is demonstrably untrue, but there is no regulatory oversight anywhere in the RHNA process that will halt a project when there is no water to support it. If the water plan is based on faulty assumptions, the project will glide through to approval making it nearly impossible to create a reliable water supply.

Challenging RHNA is not possible. Courts say they have no jurisdiction. Challenging the water is one of the few areas where housing allocations can be reduced but it’s not part of the regulatory process. In “Show Me the Water Plan (E. Hanak/PPIC)”, the paper states that “planning laws (SB 221 & SB 610) rely largely on citizen enforcement rather than regulatory oversight by the state” and “that citizens can challenge the responsible local agencies in civil suits.”

Challenging water supply has been done from time to time by highly motivated groups of citizens. In “California Water Planning 2009 Vol 4 Reference Guide”(R. Waterman) this study described one such instance when a Santa Clarita group called “Santa Clarita Organization for Planning the Environment” challenged an EIR for a project involving 2,545 homes, a retail center and 42 acres of community facilities. In (SCOPE) v. county of Los Angeles, The judge agreed and the court rejected the EIR stating that the “county’s approval of the West Creek EIR is not supported by substantial evidence (of available water).”

But while its happened from time to time it’s not a process that citizens are familiar with and having citizens challenge thousands of projects a year one by one to enforce SB 221 and SB 610 (the “Show me the Water Laws”) is an undue burden. Furthering the burden, the State has legislation such as SB 1818 that allows cities and developers to squeeze more units into a parcel even when its zoned for lower densities.

Cities are not likely to challenge a developers rights to construct housing if the allocations have not been met. RHNA’s complicated process give developers the legal foundation to build new housing and sue if cities don’t cooperate, even when it is obvious to everyone that there is no water available for the project.

So where’s RHNA going to take us?

RHNA is driving up water demand. The Housing Element is updated every eight years and new RHNA allocations come out for each new refresh so what we see every eight years are just small chunks of the housing allocations which keeps the long term past and future view pretty well hidden.

Because RHNA takes its cue from DOF population projections which extend 50 years, if you want to know where RHNA is taking us look no further than the DOF P-3 projections.

These fifty year projections can swing up and down quite a bit. The 2050 projections were reduced 10 million people between the 2006/2014 and 2013/2021 but the damage is already done despite the reduced projection.

L.A.'s last RHNA allocation was 112,876 and it led to a large number of permits being approved though not all of them were necessarily built given the economic crash that occurred in 2008. However, once entitled, they stay entitled. When the economy picks up, the construction can begin. The latest RHNA allocation for Los Angeles dropped to 82,000.

The current DOF projections show the state growing to a population of 51,663,771. With this we can expect the RHNA to increase the density to increase 16% by 2030 and by 32% by 2060. A 32% increase in the City of Los Angeles suggest that water demand would increase over 938,000 Af/y if the city’s demand was held at the current 142 gallons per capita daily. That’s is about 356,000 acre-feet a year over the city’s actual average supply.

But realistically, if the RHNA process continues unrestrained by water supply, the city would have to reduce the demand to 88 gallons per capita daily to meet 2060 population targets. This is not “residential gpcd”, this is the entire city’s demand including commercial, industrial, government and residential! And what's worse.. this is just the City of LA. Imagine how disastrous and frequent droughts will be when the state hits its 16% growth target by 2030 and 32% target by 2060.

California can never have a reliable water supply unless serious reforms are made to RHNA.

(updated on 6/14/2015)

The Paper Water Years – LA’s 1995 – 2000 Water Plans

Published / by dcoffin / Leave a Comment

This is Part IV in a series describing L.A.’s water supply problems and the policies that produced it.

1995CoverIn Part III we saw how the city sought to maintain the 1985 baseline of ~175 gallons per capita daily in the 1990 UWMP while population estimates increased. As a result we saw the projected supply in the plan jump significantly from the previous plan. We also found that the DWP heavily leveraged the projected 1990 supply in the groundwater and recycled categories using water it had no chance of getting. These factors continued into the 1995-2000 UWMP's. 

The 1995 UWMP - L.A.'s 3rd Water Plan
The 1995 UWMP should best be known by the city’s acquiescence that water supply had its limits. Population estimates from the Southern California Association of Governments (SCAG) did not climb as dramatically as they had in the 1990 plan but the increase from 3.85 million to 4.25 million by 2015 (9%) was still the driving factor.

With future growth estimates continuing to drive the supply requirement of more water, DWP planners were forced to set a new precedent by reducing the per capita supply from 177 gallons per capita to 150 gallons acknowledging that less water would be coming through the Los Angeles Aqueduct due to recent court ordered restrictions of Mono Basin water and at current allocations, future growth would have demanded ridiculously large amounts of water that couldn’t be met.

1995GPC
Figure 1 - Big jump to reduce per capita supply

If the DWP planners tried to sustain the 177 gallons per day cited in the 1990 plan, the projected supply in the new plan would have shot up to 757,000 for 2000 and risen to 886,000 acre feet per year (Af/y) by 2015!

Historically though, reducing the per capita supply to 150 gallons per day per capita would not be enough. At this allocation the DWP suggested that it would have 695,000 Af/y by 2005 and could gradually increase that to 750,000 Af/y by 2015 (Figure 1). But in the years following the approval of the plan, the actual supply figures that came in would demonstrate the DWP's failure to achieve these projections suggesting that there was far too much paper water in the projections to be viable.

DWP planners accepted that less water was going to be available through the aqueduct system and reduced the aqueduct supply by 20,000 Af/y to 360,000 Af/y in the 1995 plan.

1995PW
Fig. 2 - 1995 Projections vr. Supply

To offset the loss of aqueduct water, DWP planners suggested that they could increase the already large projections of the 1990 plans and increase the availability of recycled water to 38,000 Af/y, and groundwater to 152,000 Af/y.

Through the years though, none of these figures would ever be achieved. Recycled water averaged a mere 2,300 Af/y and groundwater averaged just 87,000 Af/y proving the plan wasn’t working.

The historical significance of the 1995 plan was that the DWP would only muster up an average of 638,490 Af/y (Figure 2). Far less than the 750,000 Af/y that it promised. Because of the paper water fueled growing deficit, the DWP would start prodding the public into reducing its demand using such schemes as tiered pricing, washer rebate programs and require that all homes install low-flow toilets before resale.

The 2000 UWMP - L.A.'s 4th Water Plan

2000GPC
Figure 3 - Lower per capita and rising demand

L.A.'s fourth water plan might best be known as having to largest projected supply that the DWP said it could meet of any of the city's UWMP's. This monster projection occurred even as the department further reduced the gallons per capita daily water supply. The reasons were due to estimated population projections supplied by SCAG.

The new SCAG population estimates started out at 4,035,305 by 2005 population and would grow to 4,856,887 by 2020. These new population figures when figured into the new per capita allocations created a demand that would skyrocket to almost 800,000 Af/y.

The 2000 UWMP lowered the 'year 2005 supply per capita' of the previous plan from 154 to 150 gallons per day and from their it would ratchet down the consumption further to 147 gallons per day by 2020. (Figure 3)

But the lower allocations would still generate a sharp rise in demand. The DWP said it could supply 718,000 Af/y of water in 2010 and sharply increase in to 799,000 Af/y by 2020. The increase though didn't come from increased recycle and groundwater.

Figure 4 - 2000 Projection vr. Supply

Perhaps realizing that developing a recycled water system and pumping more groundwater was not paying the dividends they predicted earlier, the city ended its long standing resistance to relying on pricier MWD water and would ratchet up purchases of water from 200,000 to 298,650 Af/y which would nearly equal the aqueduct supply level.

Planners were forced to lower the recycled water projections 28% from 38,000 to 29,350 Af/y. Groundwater projections fell only slightly from 152,000 to 150,000 Af/y but aqueduct projections fell significantly from 360,000 Af/y to 321,000 Af/y.

The historical significance of the 2000 UWMP was that the DWP would only be able to deliver an average of 617,000 Af/y from 2000 to 2014 which was well under the promised 757,000 Af/y by 2015 and light years from the 799,000 Af/y it said it would have in 2020 to meet the city’s growth. (Figure 4)

NEXT:  2005 and 2010 UWMP's