Tag: Groundwater

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.

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

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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

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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.

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

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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

L.A.’s Drought and Growth are Built on Paper Water

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L.A.’s recent drought has been going on far longer than the statewide drought. California’s last drought was declared in 2008 and ended in 2011 and another declared in 2015.  L.A’s drought was declared in 2008 and was never rescinded. So why has L.A.’s drought been so persistent and growing by the day? This brings on another question we should ask is how does the city reconcile the endless approvals of new construction during a persistent drought?

The short answer to both is that in order to provide evidence of sufficient water supply for projected growth, the city’s UWMP (Urban Water Management Plan) has been reporting that is has far more water available to it than it can get. uwmp2010Every UWMP from 1990 till now has projected supplies that exceeded 700,000 AF but when we look back at DWP records from 1990 to 2004 we find that the city’s total supply averaged just 627,000 Af/y. Since 2005 the average has fallen even further to just 590,000 Af/y. Simply put, the DWP has never met their projections and that has steered us head-on into a drought.

When DWP officials are asked why they haven’t met the projections cited in the UWMP, using a little spin they tell you that conservation efforts reduced demand and they didn't need to import as much as projected.

This routine answer however is disingenuous since the projections include future growth and clearly the DWP hasn’t met that expectation given today’s restrictions on water. The 1985 UWMP set the city’s baseline water at 175 to 176 gcpd (gallons per capita daily). This number reflected the current level of water to residents, businesses, and industry, it included various conservation programs such as low-flow hardware devices and left room for projected population growth to 3.41 million by 2010. At this level the city cited that it would be able to meet the demand with a very reachable water supply of 667,300 Af/y.

In 1990 however, the city’s population increased faster than the population projections that were cited in the earlier plan. Population projections in the new plan were now 14% higher and in order to maintain a similar per capita supply level and still meet projected growth, the plan’s total demand and supply projections jumped 13 percent to a not so believable 756,500 Af/y by 2010.

In each of the subsequent plans from 1995 to 2010 would continue to cite available supplies over 700,000 Af/y and as high as 799,000 Af/y.

Conflicting Demands

So now the city was confronted with two conflicting demands. The first would be to provide enough water from a now shrinking supply that once averaged 680,000 Af/y and has now fallen to just over 610,000 Af/y and still meet the city’s need. The second was to show that its supply was growing and that it would be sufficient for continued growth.

unnamed-(3)In an attempt to solve the first problem, the city’s 1995 water plan would have to ratchet down the per capita rate to 150 gallons per day to lower the total demand otherwise we would seen demand in excess of 875,000 Af/y. However even 150 gallons per day wouldn’t be enough over the short term and the city would also have to implement more draconian methods to lower the per capita further by imposing an Emergency Water Conservation order on single family residents and reducing residential billing unit allocations.

The second problem to show a growing water supply over the long term to meet the city’s growth ambitions would require a little sleight-of-hand by the DWP using ‘paper water’.

Paper Water

Paper water by definition is “water that an agency says it has available to it, but its water that is difficult or impossible to access.” and paper water can be measured by the gap between what an agency says it has available to it, and what it eventually gets.  The wider the gap, the deeper our problems.

California’s water laws require that planning agencies, and developers show evidence of current and future water availability for their project. EIR’s and water supply assessments all rely on the projections cited in the UWMP so there is a great deal of pressure on the DWP to show that the water supply is growing, where the supplies are coming from and how much. If the water plans did not show evidence of future water availability that was sufficient to match population projections this could greatly hamper the approval of their projects and possibly stop them cold. In fact some cities in California today have stopped issuing water meters to new subdivisions for residential because they have no surplus of water.

So where do we find the DWP’s paper water? With a little digging into the city’s past and current water plans we can find it in literally every category of the city’s water portfolio in literally every water plan.

Paper Ground Water

City never met its groundwater projections
City never met its groundwater projections

Our first stop to find paper water is in the DWP’s groundwater projections that are cited in each of the UWMP’s approved by the city between 1990 and 2010. The accompanying groundwater chart shows us a 79,500 Af/y gap between what the DWP says it would have to meet the city’s growth and the actual amount of groundwater the DWP had access to.

For example if we look at the groundwater projections in the 2000 UWMP, groundwater was projected to contribute 133,000 Af/y by 2010. However the average amount received between 2005 and 2014 was just 66,431 Af/y creating a 56% deficit of what they projected. This 56% is what we call paper water because these same conditions arise in each of the other water plans approved by the city. 36% of the groundwater projection cited in the 1990 UWMP was paper water. 51% of the 1995 UWMP’s groundwater was paper water, and in the 2005 UWMP it is 39% paper water.

Over 24 years this paper water would represent about 1,088,000 AF of water that the DWP said it would have to meet projected growth but over time it would never receive.

The city never stood much chance to meet these projections. Growth, fueled by paper water is at the center of blame. LAStormwater.org states that the city captures just 27,000 Af/y of storm water a year to recharge the underground storage. This low rate is attributed by ULARAwatermaster.com to the city’s built-out growth which has impeded the capture of groundwater because so much permeable soil is paved and built over. The Upper Los Angeles River Area Watermaster reports that most of today’s groundwater recharge comes primarily from LA Aqueduct and Metropolitan Water District imports. Further restricting groundwater pumping is that many wells were found to be contaminated in the mid 2000’s and had to be taken out of service.

Paper Recycled Water

City never met its recycled water projections
City never met its recycled water projections

Our next stop where we find paper water in is the DWP’s Recycled Water projections. Urban Water Management Plans between 1990 and 2005 all projected rapidly growing recycled water supplies that later would never be realized.

The Recycled Water chart shows a huge gap indicating that up to 91% of water supply the city claimed it would have access to for future growth is just paper water.

In one example the DWP projected in the 1990 UWMP that the city would have 32,800 Af/y of recycled water by the year 2010. This number like all projections would be used as evidence of future growth by planners. But this water would never be realized. The actual average reported yield between 1995 and 2010 was just 2,921 Af/y which was 29,879 Af/y below what was promised. This 91% deficit is our paper water.

We find the same results in each of the other recycled water projections of plans that would follow. If we look at the 2010 projection in the 1995 UWMP, 84% of the 29,000 Af/y that was supposedly available ended up as paper water. In the 2000 plan, 75% of the 18,400 Af/y projected for the year 2010 ended up as paper. In the 2005 plan 65% of the 16,950 Af/y projected was paper water.

Over 24 years this would represent at least 384,096 AF of paper water that the city said it had access to as evidence that it had sufficient supply for projected growth but it never received that water.

Oddly, the DWP’s latest 2010 plan appears to be doubling down on paper water by citing that it will have 59,000 Af/y available to it by 2035. Already it looks like the first milestone in 2010 of 20,000 Af/y will be missed by a large margin which further demonstrates how that L.A’s drought and growth are built on paper water.

Paper Aqueduct Water

City never met its LA aqueduct projections
City never met its LA aqueduct projections

The city owned aqueducts have been our primary source of water since 1913 but in recent years it has also become the UWMP’s largest contributor of paper water.

Even though the aqueduct’s projections in each plan would fall incrementally due primarily to environmental mitigation, the percentage of paper water would increase from 38% during the 1990 UWMP reporting period to 54% by the 2005 UWMP reporting period.

In this example, if we look at the 1995 UWMP, aqueduct water was projected to be 360,000 Af/y which included surpluses for future growth. But that water never came down the pipe. The actual total reported supply was just 217,258 AF/y between 2000 and 2014 was 142,274 Af/y below what was promised. This meant that 43% of the projected total was paper water.

The 2000 UWMP projected aqueduct supplies to be 321,000 Af/y through to the year 2020. However to date the average supply has been just 210,132 Af/y meaning that 45% of the projected supply was paper water. The 2005 UWMP would look worse. It projected 276,000 Af/y through the year 2030 but the supply beginning with its reporting period has been just 173,393 Af/y meaning that over half of the water projected in this plan, 54% was paper water.

Over 24 years this would represent at least 1,863,000 AF of paper water that the city said it had access to as evidence of a growing supply but it never received to this date.

Paper MWD Water

lagado
Projects in L.A. promise that MWD will meet any city shortfalls in the future.

It’s hard to describe MWD water as paper water since most of the DWP’s projections for MWD water were greatly under reported from what was actually received. Typically when the City of L.A. fell short of water which was most of the time, the MWD would step in to fill in as much missing supply as it could. But water is a zero-sum resource and if you take more than your share of water, you’re taking it from another agency. There are limits to what the MWD could supply and history suggests that 423,000 Af/y was L.A’s limit.

MWD water can be described as paper water because each of the city’s UWMP assures that any shortfall of city owned water would be made up by MWD water which is a promise that can’t be met. That is promise made to planners more than it is to the city’s residents.

Paper Conservation

This category is a new form of paper water that was just introduced in the 2010 UWMP. In past years, the term conservation applied to water supply that was already received by the city and the value attributed to it was measured by the reduced number of gallons per capita. As mentioned at the beginning of this article, the DWP originally allocated about 175 gallons per capita in the 1985 and 1990 water plans which includes residential, commercial, government and industrial uses. The city’s conservation programs since then have reduced this to 141 gallons per capita using primarily Tier pricing and low-flow hardware devises. More recently it included so-called “turf buy back” and enforcement measures. In its simplest terms, ‘conservation’ is the ability to stretch out a given supply.

The DWP in 2010 decided to turn this idea on top of its head and count conservation as a source of supply that adds to the city’s total supply. This appears to be another attempt to produce more water on the ‘books’, but water that in time will not be accessible. The 2010 UWMP appears to be suggesting that the city will receive 14,180 Af/y of new water by 2015 and up to 64,368 Af/y by 2035.

Paper Transfers

Neenach Pumping Station (Google Earth)

This is another new category to the UWMP. Transfers may also turn out to be another form of paper water since water transfers from other agencies is solely dependent on them having surplus water which is in doubt these days.

Most of the agencies the city could bargain with also depend on the SWP to supply them water. The SWP has been seriously cutting back allocations to their customers which includes the MWD.

The 2010 UWMP projects that it will receive 40,000 Af/y through the Neenach pumping station. Only time will tell if this is a viable and reliable source of water.

Summary

Overall the amount of water the city promised for future growth and did not meet is staggering. Each UWMP would follow a familar pattern. The first of the five year milestones would be adjusted relatively close to the current supply level and in the following 10, 15, and later milestone years, paper water would contribute to ‘unlikely to be reached’ levels of supply.

When we look at the 1990 UWMP for example we find that the total annual water supply projected by the year 2010 was 756,500 Af/y but the actual supply that came in during the scope of this plan was just 624,283 Af/y. Paper water represented 17% of total projection given the shortfall of 132,217 AF per year. The 2000 UWMP would raise the projections astronomically to 799,000 Af/y but as actual supplies came in, the average so far to date is just 617,645 Af/y thus producing a deficit of 181,355 Af/y per year.

Over 24 years, this would represent 4,352,000 AF of paper water that the city said it had access to as evidence of a growing supply but it never received to this date.

From the standpoint of development and the planning department, paper water is a good thing because the EIR’s, WSA’s and smaller projects that fall below SB-221 reporting requirements can all be assured that whatever their demand is, it will “fall within the available and projected water supplies” over the 20 to 25 year scope of the plan they are citing. Whether the city falls into a permanent drought is irrelevant to the approval process but it has huge repercussions elsewhere since the unmet demands means that the water must be found elsewhere when conservation isn't enough. These demands might be met by fallowing farmlands in the South San Joaquin valley or eliminating their supplies altogether forcing them to drive wells deeper to meet their shortfalls.

From the standpoint of residents however, paper water means higher utility bills, lower tier allocations, and lower property values for the unlucky homeowners who have high density built behind their yards but worst of all, it means the city's water supply is no longer reliable.

This article originally appear on City Watch LA.

Dissecting L.A’s Paper Water – Groundwater

Published / by dcoffin / Leave a Comment
Now that we find that the City of Los Angeles routinely props up its water portfolio using 'paper water' so where do we find it? We first find evidence of the city's reliance on paper water in the groundwater projections cited in each of the Urban Water Management Plans between 1985 and 2005.
GWprojA
Groundwater supply is just 67% of UWMP projections.
The chart at the right plots the gap between the actual groundwater supply the city had access to and the anticipated supplies that each UWMP projected. The gap between the two is the paper water that would be used to as evidence that medium and high density projects going through the planning process would have sufficient water when in fact they didn’t. The city routinely projected supplies that ranged from 103,000 AF to 155,000 AF during that period.  Including a brief period between 1997 and 2000 of exceptionally high pumping, the actual amount of well water produced by the city was 33% below expectations. Far below the city's expectations and glossy presentations that suggested that growing groundwater supply would help the city meet its needs and allow its growth ambitions. Despite the city's average of just 71,000 AF since 2001, the city's current 2010 water plan continues propping up it's paper water inventory citing that it should an average of 107,426 af/y in available groundwater supplies between the years 2020 and 2035. Between 2000 and 2014 the city's groundwater supply would remain flat at 71,059 af/y which is far below any of the past UWMP projections that ranged from 103,000 af/y to as high as 152,000 af/y. GWToTotal Paper Water This gap between 'projected or anticipated supply' and 'actual supply' is an unfortunate characteristic of the city's water supply. It's a promise spanning 5 water plans and 25 years that was used to mischaracterize the city's supply to approve high density development. The City's failure to meet groundwater projections stems primarily from the fact that it is just storage. The City of Los Angeles Stormwater Program reports that the city captures just 27,000 AF of water to recharge the underground storage. The reason for this can be found in Upper Los Angeles River Area Watermaster reports which state that "The continued growth of residential, commercial, and industrial developments has required that more water be imported to supplement the local groundwater supplies in ULARA over time. Imported supplies to ULARA are from the Los Angeles Aqueduct and from MWD". Because of the extent of development in the valley, much of today's potential groundwater supply is simply channeled into storm drains and down the LA River. Secondly, ULARA reports that many of the San Fernando Valleys groundwater pumps have been taken out of service due to groundwater contamination.

L.A.’s Paper Water Problem

Published / by dcoffin / Leave a Comment
Part IV in a series describing L.A.’s water supply problems, the drought and the policies that produced it. L.A.'s PAPER WATER Urban Water Management Plans of 1990, 1995, 2000, & 2005 had all projected huge demand requirements and provided us with solutions on how it would met. However, as each superseding UWMP was approved, it left behind a growing legacy of plans with a history of projections that were never met. faucetOver time, it became apparent that this is not simply a miscalculation but likely an intentional effort by the city to mislead the public using ‘paper water’. Paper water is water that utilities claim they have access to, but is difficult or impossible to access for various reasons. You can't drink paper water or cook with it but you can make lots of promises with it. The 2009 California Water Plan Update describes such a scenario in an article titled Water for Growth (E. Hanak/PPIC) stating that "A majority of utilities reported considerable normal-year surpluses, both now and 20 years hence, raising the possibility that many are banking on “paper water” for their margin of comfort." Generally the City of Los Angeles hides its supply shortage behind promises of water that it could never actually deliver on such as groundwater, recycled water and LA Aqueduct water. Large Projects One very typical example where paper water was cited would be the massive Playa Vista development that was approved in the early 2000's. The project's water demand which was based on the 2000 UWMP stated: "LADWP anticipates annual water demand within the Department’s service area to increase by 2010 to between 718,000 AF (in a normal year) and 761,000 AF (in a dry year), which represents a demand increase of 5.7 percent to 12.1 percent, respectively, between 2002 and 2010.
2000PW
Fig 1 - Projected Supply v. Actual Supply
This increased demand in water use is accounted for in LADWP’s Final Year 2000 Urban Water Management Plan Update, and LADWP has identified various means and options for securing adequate water supplies to meet the needs anticipated for 2010, as well as through the year 2020. Ref: EIR No. ENV-2002-6129-EIR" However the anticipated annual supply of 718,000 AF never materialized by 2010 nor did the 757,000 AF promised by 2015 as shown in Figure 1 at the right. In 2010 the city water supply was 25% below the projection cited in the Playa Vista EIR at just 540,229 AF and it fell even further behind by 2015. The average yearly supply of 617,645 af/y between 2000 and 2014 was 23% below the projections 2015 projection. Neither aqueduct water, groundwater or recycled water projections were met. The promise of up to 799,000 af/y of water cited in this EIR is what we would call ‘paper water’. It's this promise of water that contributed to the approval of the project but it was water that can never be had.
2000uwmp
Fig 2 - The 2000 UWMP's Paper Water
This particular development is not an isolated situation. Literally every project in the city that has been approved since 1990 cites the inaccessible water in the city's UWMP. Prior and subsequent UWMP's also projected supply levels that could not be achieved. The 2005 water plan cited 705,000 AF this year and up to 776,000 AF by 2030. Even the current 2010 UWMP has similarly projected supplies in excess of 710,000 AF by 2035. The City of Los Angeles has not been able to produce water supplies in excess of 690,000 AF since 1989. Smaller Projects Benefit by Paper Water Large projects with 500 units or more are required by SB-221 to obtain written verification that long term water supply is available for the project. This written verification goes into a tedious analysis of the projects demand and then always comes to the conclusion based on the UWMP's paper water that "adequate water supplies would be available to meet the estimated water demands of the proposed developments..." The thousands of smaller projects with 499 units or less that are winding their way through the planning process are exempt from this formality.  They need only cite the current UWMP which includes all existing and planned future uses of the city's water supply then come to the same conclusion that "that adequate water supplies would be available to meet the estimated water demands of the proposed developments..." To date, literally every project approved since 1990, both small and large projects alike have been the beneficiary of paper water but it hasn't benefited residents. Paper Water may be Political Cover The city's most recent 2010 UWMP greatly lowered projections but that had not stopped or slowed down the approvals of large or small projects alike. The reason why could be found in a statement made by the DWP back in 1990 saying that approving projects is ultimately a "political decision to be decided by the Mayor and the City Council".  So it's likely that the water departments insistence on such large water supply projections year after year is to provide political cover to for approving all of the developments making their way through the planning process. In the 2009 California Water Update, the article Water For Growth alludes to that by noting "...even in jurisdictions with municipal water departments, elected officials may take a shorter-term view of resource adequacy than area residents do. If—as is often asserted—land-use authorities are aligned with predevelopment forces, they may be inclined to favor growth, even if it means higher costs (or a loss in property values) to the community down the road."  

L.A.’s First Water Plans – The 1985 & 1990 UWMP

Published / by dcoffin / Leave a Comment
In 1983 the State of California passed the Urban Water Management Plan Act that required water suppliers to provide a water plan every five years. 1985UWMPCoverThe Urban Water Management Plan (UWMP) is rich in information as it identifies the agencies sources of water (aqueduct, groundwater, imported), amounts of water available from these sources, methods of conveyance, current and future water uses, projected demand, current and future conservation methods, demographics, population density and growth, housing mix, commercial/industrial/governmental demand, etc. The importance of the UWMP is that it is used as a guideline for making public decisions concerning water and is cited in planning documents, water supply assessments. But the UWMP can also be seriously misused when 'paper water' is inserted into the plans which provides a misleading assessment of the water supply or when city officials simply rubber stamp the findings without any sort of reassessment given current water supply availability. The City of L.A.'s UWMP's are both fascinating and disappointing in that they paint a picture of great expectations, a long term failure to meet demand and worse, a misleading assessment of the city's true water supply. What follows is a retrospective look back at previous UWMP's. What we find is a blueprint to a permanent water deficit. The 1985 UWMP - L.A.'s First Water Plan
Figure 1
The 1985 UWMP was the first state mandated water plan published by LADWP. This first time report was an honest and useful assessment of the city's water supply at the time. The plan assumed the city would receive a constant 470,000 Af/y supply through the Los Angeles aqueduct, 103,000 Af/y of groundwater and a small but growing reliance on MWD water between 1986 through 2010. From a planning perspective the most important part of the UWMP are the tables that show the projected water requirements at 5, 10, 15, and 20 increments for average years. The tables break down how much water the city assumes it will receive through the aqueduct, local groundwater, MWD, and recycled water. It's important that these projections meet the actual supply 5, 10, 15, and 20 years later because they are used in environmental impact reports and water supply assessments as guidelines for future development. If the actual supply doesn't meet the projections then we can assume we are creating a water supply deficit. (more…)
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