California’s Groundwater Basins

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Interested in identifying your California Groundwater Basin? I downloaded California Department of Water Resources groundwater basin .shp file and started a mini project converting it to a .kml file and colorizing each basin so that you could view them in Google Earth.  The result is a beautiful colorful maze of groundwater basins throughout California.

Feel free to download it from the KML library link on the right side or here. You can also find an interactive map at the Groundwater Information Center.

You will need Google Earth to view it.

UWMP Comment Period Quietly Passes Unnoticed

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shutterstock_101516563In a city with nearly 4 million people, there are probably just a few dozen that even know what the Urban Water Management Plan is and even fewer that knew March 16th was the last day to comment on it.  Comments that are submitted during the public comment period are published near the end of the UWMP and for the most part go unseen by the general public and decision makers such as the LADWP Board of Commissioners, the Los Angeles City Council and Mayor who deliberate over the plan and approve it. Perhaps the Los Angeles Department of Water and Power prefers it that way.

Having watched this process in 2010 and again in 2015, I am a bit surprised and dismayed that the local print media such as the Los Angeles Times and the Daily News don’t really report on the UWMP especially given how distressed our water supply situation is. They do often report on the shortage and water wasters. A quick search of the and web sites for “urban water management plan”, I could find no evidence  that either paper had reported anything about the city’s most important planning document.

This lack of coverage by our print media on the city’s UWMP is a real disservice to its residents. It’s also a disservice to our elected officials who I found have very little understanding of the water supply figures in this document. If the media would question them on it perhaps city officials would take this process more seriously.  Elected and appointed city officials typically just approve documents like this, even seriously flawed UWMP's  without much discussion because they don’t understand it.  

The 2015 Draft UWMP is totally inadequate in its current form. It mischaracterizes the city’s true water supply outlook and needs to be rewritten to include meaningful, measurable, achievable water supply projections that planners, developers, and residents can be assured the department can meet.

As a service to our local media, I've posted my comments to the draft here. This would be a good place to start should you choose to report about the upcoming deliberations on the UWMP over the next few months.

Los Angeles Aqueduct Year End Report

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With the Water Year ending last September, this is a look at the Los Angeles Aqueduct supplies from 1975 to 2015. Most of the hard reductions were due to Courts ordering the LADWP to permanently release water back into the Mono and Owens Basins between 1985 and 2007 . The last three years have been due primarily to the State's drought. Hopefully that will rebound back to the new normal of 210,000 to 220,000 AF levels over the next year or two.


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.  

Thoughts on the LADWP 2015 Draft and UWMP Process in General

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If there ever was a reason for the State Department of Water Resources to vet UWMPs that are submitted to it, this should be one of them. For 30 years, the Los Angeles Department of Water and Power’s practice of reporting water that it can't access has undermined public transparency, making it appear that the city water supply was well situated for growth. The city’s long, persistent drought is a result of this activity. Allowing utilities (LADWP is not alone) to report access to water they have no access to makes a mockery out of the so-called ‘Show Me the Water Laws’ and the State's water laws in general.

The practice threatens water supply because once development is permitted using fictitious future supply data, the predictable shortages appear which have to be followed by hard choices when other equally important users feel the impact and assert their rights. Who should make the sacrifice? Agriculture? Fish? Hydropower? The environment? Perhaps we should connect growth with water and make the cuts there.

Urban Water Management Plans should be clear and easy to understand and accessible to the public. When shortages are projected, the UWMP should also offer enough detail to decision makers and the public what the economic costs and access to water will be if development continues over the 20 year lifetime of the plan. More important than knowing there will be 611,800 AF/y in 2020, residents should be advised on how it will affect their monthly allocations and how much higher their billing costs will go up.

Today's Urban Water Management Plans are written in wonkish, 'members only' style that excludes public participation in its formation and approval of the document. The style also excludes the public from the planning process where it is ultimately used. I know that many planners and decision makers don't understand the document. They instead look to the singular paragraph in the EIR that says...


This needs to change.


LADWP 2015 Report Card on UWMP Projections

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With the close of the 2015 water year last September, it's time to step back and take a look at how well the LADWP met its first five year projections that came from the 2010 Urban Water Management Plan. EIR's winding their way through the planning department use this data to presumably assure us that there will be sufficient water supply in 5, 10, 15, and 20 years into the future.

So how did the 2010 UWMP fare in its first five years? Did the department meet their total supply projections? Did they meet the groundwater, recycle, transfers and stormwater projections? What does this mean for the new 2015 UWMP that is being drafted today and soon be released for public comment?

Let's take a look and compare this years water deliveries to the last two UWMP's.

  • A Look at the Total Supply

The following two charts show us the total supply entering the LADWP water supply system which includes all of the categories mentioned above.

All Sources - 2005 All Sources - 2010

It's not pretty. In both charts we find that the department has not been meeting the supply projections that EIR's routinely cite in the planning documents assuring the city of sufficient supplies. Supply levels are far below both the 2005 and 2010 UWMP projections and trending down. The failure to meet these projections while planning departments continue to green-light projects contributes heavily to the city's water shortage.

The next sections will tell us where the department is falling short in the city's water supply portfolio.

  • Source: Aqueduct

Having already been battered in 2013 and 2014, its hard to imagine the Los Angeles Aqueduct deliveries getting worse but it did. 2015 turned out far worse for the aqueduct as it's deliveries fell to a mere 31,766 AF for the entire year. As a point of reference, 25,000 AF would normally be considered an 'average month' prior to 2000.

The city's aqueduct is the largest city owned contributor to the city's water supply portfolio but in April, May and June it fell behind even recycled water! EIR's circulating through the city's planning department assured planners that by 2015 the city would be receiving 252,000 AF of aqueduct water each year.

Aqueduct 2005-2010GW1

Clearly the weather pattern over the Eastern Sierras in the last three years has had an effect on the aqueduct supply as it has averaged just 58,000 AF/y, but even if the department had maintained the 2000-2012 average supply levels, it would still be below the departments long term projections.

Aqueduct Grade: F

  • Source: Groundwater

Groundwater is the city's second largest city owned contributor to the water supply portfolio. After decades of consistently missing supply projections and losing what credibility it could have earned, the LADWP was forced to lower its projections by reducing it's groundwater projections by 62 percent. Having done that, for the first time in 16 years the department actually came out ahead in 2015.  

But we can't get too excited. The department's average production since 2000 was just 74,000 acre feet per year which is far less than the assurances found in EIR's stating that the LADWP will produce an average yield of 96,000 acre feet per year by 2020 and climb to over 110,000 AF/y.  Groundwater production is not a reliably consistent year-to-year source of supply when pumping exceeds the San Fernando basin's average recharge rate. One or more years of heavy pumping have to be followed by several years of reduced pumping to allow for the basin to recharge.

Groundwater Supply Grade: D

  • Source: Recycle

While the LADWP projected gains for recycled water in the ten's of thousands of acre-feet, it's success over the past two decades could only be measured in the hundreds of acre-feet.  EIR's circulating through the city's planning department over the last five years assured planners that by 2015, recycled water would be contributing 20,000 acre-feet per year to the city's portfolio.  However, the department didn't even come close with just ~9,800 AF entering the system. This year we found that the missed its 2010 UWMP 5 year milestone by over 50 percent. 

2005-2010RCY 2010TR

Past UWMP's regularly projected that the department would produce over 30,000 AF/y and the latest 2010 plan raised this further promising planners 59,000 Af/y by 2035. The chance of this happening is as remote as seeing the department replace all its aging water mains by 2035.

The Department of Water Resources says that if utilities can't access water they say they have access to, this is called paper water.

Recycled Water Grade: D

  • Source: Transfers

EIR's circulating through the city's planning department assured planners that by 2015, water transfers of 40,000 acre feet each year would be contributing to the city's supply portfolio.  The department constructed the $40 million Neenach Pumping Station Turnout Facility Project in the Antelope Valley to facilitate transfers of water from the Central Valley and Northern California but no sellers were found, no contracts were signed and the promised 40,000 AF never entered the system.

'Transfers' are sales of water rights between one entity to another. To effect a transfer the city would have to find willing sellers such as water agencies or farms with surplus water and sign contracts for 40,000 AF/y of water.

LADWP's Transfers certainly falls under the definition of paper water.

Interestingly, LADWP's entry into the water market puts it in direct competition with its main provider of imported water, the Metropolitan Water District.

Transfers - Grade: F

  • Storm Water Capture

Storm Water Capture is composed of two subcategories of water, Harvesting (Rain Barrels & Cisterns) and 'Increased Groundwater Production'. Of the two, that later is not scheduled to produce water until 2020.

Since the department created this category of water, EIR's have been assuring city planners that Harvesting will reduce the city's demand by 2,000 AF by 2015.

The problem with this category of water is that it never enters the city's water system and thus cannot be certifiably measured.  This creates doubt to whether the 2,000 acre feet per year is real water or just paper water. When LADWP managers were questioned about this they admitted that they do not have the ability to physically measure this water and would instead rely solely on models.

I have serious doubts that models could withstand a legal test in courts if an EIR were challenged because there is no way of knowing how many of the rain barrels were distributed, how many are actually being used or repurposed and how much water they actually captured. Furthermore, it would take 11 million rain barrels to store 2,000 AF of water that roughly amounts to 27 rain barrels per single family household.  

I firmly place Harvesting in the category of paper water. 

Harvesting - Grade: F

2005-2010STRM 2005-2010CV
  • Source: Conservation

EIR's circulating through the city's planning department assured planners that by 2015, the city would be receiving 8,178 acre feet of water per year categorized as Conservation.  However, Conservation is not a source. Water supply entering the city water system cannot be counted twice. New water comes into the city system as groundwater, recycled water, or imported water through the aqueduct and MWD.

When residents make a concerted effort to conserve and the resulting savings is redirected elsewhere, 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. Double-dipping is not a legal accounting method.

If the LADWP wants to demonstrate to the public how much the savings is made by conserving, it needs to put this on the demand side of the equation by reducing the gallons per capita daily. Until then this is just another form of paper water.

Conservation - Grade: No grade. Not a supply

  • Summary

Given how important it is to meet the assurances that planning documents such as Environmental Impact Reports cite, we would have to assign an 'F' grade to the LADWP for failing to meet its own water supply projections.   

One might think today that the city's shortage is just a recent phenomena, it isn't. Here is what the LADWP's updated record looks like going back to 1990.


Meeting Supplies cited in EIR's - Grade: F


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!


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