How Much Paper Water Costs

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!

 

How Effective is L.A.’s Conserving Water by the Glass?

City of Los Angeles Emergency Water Conservation Order regulations prohibit restaurants and other public places from serving water to customers unless they specifically ask for a glass of water. So how much of a reduction of water does this city ordinance make and does it have any practical effect on reducing L.A.'s demand?

waterglassWe'll set up an admittedly unlikely scenario where every person 15 years and older in the City of Los Angeles goes out to eat in a 'sit-down restaurant' every other week and has a 16 ounce glass of water served to them.  The 2010 US Census tells us there are 2,956,181 people in the city that fall into that age group.

The size of the average glass is probably on the big side, the number of patrons and frequency of eating out is probably a bit high side, but over estimating the demand created by serving water is better than downplaying it for the purpose of this article. 

Under this scenario, restaurants would serve about 9.6 million gallons a year. A little more if we add washing the glasses but again, it's highly unlikely L.A. City restaurants with 'waited' tables are seeing 77 million patrons a year.

While 9.6 million gallons sounds like a lot, in the larger picture it's just 29 Af/y in a city whose historical demand is over 620,000 Af/y or 202 billion gallons. I'll set aside the meaningless Olympic size swimming pool comparisons that are often made in the media to describe water volume and instead describe what the reduction means in a more practical way:

  • 29 Af/y is roughly the amount of water 325 people would use over a period of one year in a city of 4 million.
  • 29 Af/y would provide only 9 percent of the 1,444 unit SOLA project projects demand that the LADWP recently recommended for approval.
  • 29 Af/y is enough to support only about 89 average single family residential units for one year in a city with over 627,300 units.
  • 29 Af/y is enough to support only about 140 average multi-family residential units for one year in a city with over 764,400 units.

So how much is saved? None really. The restriction on serving water to restaurant patrons has no practical effect on reducing demand in a city whose demand continues to grow on a daily basis. The restriction hasn't helped reduce the city's deficit since it was imposed in 2007. In fact, the deficit has deepened in spite of it. This restriction in the city ordinance is merely a legal reminder that the city has been operating under a water deficit for the last eight years.

L.A. City Prodded to Grow Without Additional Water

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.

Dissecting L.A.’s Water Supply – Conservation & Stormwater Capture

With the availability of imported water dramatically falling and local supplies (recycled water and groundwater) not meeting projections, the LADWP had to scramble to come up with ways to develop new supplies or create the perception of sufficient supplies for future growth. Or both.

new waterThis would require some creative thinking by the department pie charts in past water plans cited only four sources of supply that make up the city's water supply which were the LA Aqueduct, Groundwater, MWD, and Recycled water.

In the 2010 UWMP the department settled on three new sources. Two of these sources were 'Conservation' and ‘Stormwater Capture’. The third will be discussed at a later date.

To date, five years after they were announced, neither of these sources have been measured and reported to the city’s Board of Water and Power Commissioners in its monthly reports so this information is not made public. Without reporting this, there is no way to independently verify the claims made in UWMP's and Water Supply Assessments.  The reasons they are not reported should be apparent as we discuss them below.

CONSERVATION – As described in the 2010 UWMP, conservation is a “continuation of rebates, incentives, promoting new technologies and reduced outdoor water use.”

There is a problem with this description however in that it is not ‘new’ water. Conservation is not a source of supply that contributes 'new' water to the 700,000 Af/y supply which the LADWP says will grow to by 2030. It merely stretches out water that was already been counted as new water. This is essentially a form of double-dipping so it should be treated as paper water.

When individuals use less water for any of the reasons described above this doesn’t add to the supply, it merely stretches out the supply or allows it to be re-allocated to other uses such as new construction.

systemreport'Conservation’ doesn't show up on monthly reports to the Board of Commissioners because it is not new water, and it can’t be precisely measured. Furthermore, whatever figure can be estimated it would have to show up as a credit which would help lower the city’s projected annual demand. If the department lowered the projection then it would not show a growing water supply which would presumably make WSA’s a harder sell.

STORMWATER CAPTURE – The ‘Stormwater capture’ supply is divided into two sub-categories that together, the department claims will produce 25,000 Af/y of water. These sub-categories are ‘Increased Groundwater Production’ and ‘Capture and Reuse (Rainwater harvesting)’.

In the first sub-category,  Increased Groundwater Production is a source that the department says will produce 15,000 Af/y of new water. LADWP is rehabilitating and increasing the capacity of its spreading grounds that will result in the increased groundwater production. When stormwater is captured, it is directed towards spreading grounds where the water percolates or is pumped into the ground for storage and later pumped out as groundwater pumping. This new water adds to the supply and can be measured as stormwater enters the spreading grounds.

However, because these figures do not show up on monthly reports to the Board of Commissioners, there is no way to verify if the department is meeting its 15,000 Af/y targets and until that is done, this claim should be treated as paper water.

barrelIn the next sub-category, Capture and Reuse (Harvesting) is a source that is divided between rain barrels and cisterns. The department claims that Rain barrels will contribute 2,000 Af/y and up to 10,000 Af/y in 2035 to the supply. This figure is highly suspect at best because it can't be measured and it includes a lot of assumptions that makes reaching the goal unlikely.

The department sets up a scenario to assuming 400,000 residents will have a rain barrel sitting aside a 500 square foot roof located in an area where it rains an average of 15” per year. How they come up with 2,000 Af/y is anyone's guess. You would need 11 million rain barrels to store 2,000 AF which is 651,702,000 gallons. However, the bottom line is this cannot be verified. With no gages, no monitoring and no reporting, the department shouldn't be touting it as a supply. Treat this as paper water.

The department is even more vague about cisterns which function like rain barrels but are a much larger. The scenario the department sets up to collect 8,000 Af/y is simply that they will be sited ‘on-site for schools and governments only’. It doesn’t say how many cisterns are needed or how large they are and it doesn't say where they will be located. Here again, no gages, no monitoring and no monthly reporting to the board. Trust us seems to be the prevailing message for the Harvesting sub-category so this should be treated as paper water.

In summary, only half of the Stormwater Capture supply (higher capacity spreading grounds) can be considered new water which adds to the city's water supply. The other half (harvesting) can't be measured for participation and effectiveness so it falls into the category of paper water. And with Conservation, this is another example of paper water since it also does not add to the water supply.

To be credible, UWMP’s and water supply assessments must be based on reliably collected data from all of the historical supplies they cite as sources. Trust us isn’t good enough.

Stormwater   













Running 9 Cities Out of Water

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.

Purple Pipe Doesn’t Live Up to Hype

LADWP water plans are generally more about perception than results and 'Purple Pipe' is certainly the poster child proving that.

Purple pipe is used to distribute non-potable recycled water and is often presented as one of the departments cornerstone resources to meeting the city's water supply demand since it frees up potable water that would have been used for irrigation or industrial use. Thumb through many of the DWP’s presentations and you'll find impressive glossy photos of purple pipe that suggest that it's been making big contributions to increasing the City of Los Angeles water supply. Even the Mayor and the city’s neighborhood councils are lulled into this group think.  

purple pipeHowever when perception meets gritty reality, purple pipes contribution to the city's water supply is simply underwhelming and not deserving of so much attention. Past LADWP water plans told us recycled water was supposed to deliver be delivering ~30,000 Af/y to the city by 2015. But instead the city's been getting an average of only 7,600 Af/y.

There are several reasons for this shortfall, the biggest being the same reason the city isn’t able to effectively replace its aging water mains. The immense cost of such an effort and the disruptive nature of digging up thousands of miles of city streets in a city that is already built out and paved over is prohibitive. The department says it would take 300 years to replace its crumbling water mains. Building a distribution network of purple pipe runs into the same problems of cost and disruption.

This leaves the department to choose routes where it can get the most bang for its buck. Generally this means it has to be a customer who can use lots of recycled water and is relatively near by the filtering plant. In the city's west side for example, only a few customers like LAX, Westchester Golf Course, Loyola Marymount and Playa Vista fall into that category.

Sure it would be nice to have purple pipe running alongside the city's water mains that finally connects up to every large commercial and residential complex but that's not going to happen.
recycle

The other reason for the lack of progress is that recycled water is primarily for irrigation and industrial use. In the 1980's the city's industrial use was ~30,000 Af/y but overtime this has fallen to an average of just 19,000 Af/y. The rest would go to city parks, golf courses and new commercial/residential developments that are close enough to filtering plants that makes it economically viable to tear out a few streets and lay new purple pipe.

This is not a growing customer segment that justifies the departments claim that it will increase recycled water to 42,000 Af/y by 2025 and 59,000 Af/y by 2035.

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

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

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 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)

LA City Water Assessments Edge into the Absurd

Water supply assessments for two large projects have been approved by the LADWP water resource planners and is coming to the City of Los Angeles Board of Water and Power Commissioners on June 2 for approval. 

The LADWP cites its own 2010 UWMP claiming there is sufficient water for these two projects through the year 2035, and enough for all other "existing and planned future demands".

academy squareThe two projects that apparently passed muster are the 250 unit Academy Square Project in Hollywood and the 1,444 unit South Los Angeles Village Project in downtown Los Angeles.

The 2010 UWMP they cite projected that the city would be receiving a yearly annual total supply of 614,800 Af/y by 2015. That would be made up with 252,000 Af/y of LA Aqueduct supply, 40,000 Af/y of ground water and 20,000 Af/y of recycled water.

Given the bad news the entire state has been dealt with over the last three years and the city is begging residents to rip out turf in an effort to conserve, it would be understandable if you thought that the city wasn't quite meeting its water supply targets. You would of course be right to think that.

The problem with the assessments for these projects is that since the approval of the 2010 water plan, the DWP's total water supply has averaged just 550,887 Af/y which 10% a year short of what it needs to meet the city's needs. When we look at the categories that make up the supply we find that the recycled water supply is short of its 20,000 Af/y by 84% at just 7,392 Af/y. Groundwater to date is ahead of the 2010 projection by 60% but is unlikely to meet 2020 through 2035 annual projections due to its cyclical nature. The 2010 UWMP plan also cites 40,000 Af/y of transfers for which there is no evidence of receiving and it counts 14,180 Af/y of 'conservation' as new water which it is not.

The 2010 UWMP is stuffed full of water that simply can't be accessed and is plainly 'paper water'.

How the Board of Water and Power Commissioners can approve these projects with a straight face given the severity of the drought is anyone's guess. The city appears to be in a 'state of denial' when it comes to the shortage as it approves these projects big and small. But it's also in a 'state of crisis' when it comes to prodding the public into conserving. It can't have it both ways.

Editors note: The DWP has not met any long term water projections outlined it its plans since 1990.

A Couple of LA Aqueduct Films of Note

A couple of indie films of note. The first I'd like to mention is The Longest Straw. You gotta appreciate a few young people who recognized the importance of the Los Angeles Aqueduct that they decided to hike along the entire route to make a documentary of it. Not sure if they make the hike into some of the more out of the way locations such as the construction camps at Water Canyon, Sun Canyon or Pine Tree where Mulholland's men tunneled through parts of the Southern Sierras but 400 miles is 400 miles. That's a pretty big challenge. Secondly I would like to mention Slake: Water & Power in the Eastern Sierra. I spotted this film on the internet as I was researching the LA Aqueduct for my KML a few years ago was. I don't know if they ever finished the film but the video is very moving.
LongestStraw slake
If you know of any more please email me or tweet me with your suggestions at @dcoffin.