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.
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.
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.
In 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.
The 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
Aside 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.
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 ofImaginary 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!
This 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.
'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.
In 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.
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.
The 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.
The 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.
Continuing 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 state’s biggest challenge in meeting the population’s water supply requirements isn’t conservation, it isn’t lack of infrastructure, not storage, and not groundwater. It’s RHNA, a little known wonkish piece of legislation embodied in Government Code 65580 that's mostly known to planners, developers and city hall staffers.
What follows might sound like we’re veering away from the focus of this blog but stick with it, RHNA affects water demand (and electric power and traffic) in a very heavy handed, mindless way. You’ll see why.
State Level RHNA
RHNA (Regional Housing Needs Assessment) is a law that requires the state Department of Housing and Community Development (HCD) to establish the region’s existing and projected housing needs. RHNA prods and some might say it threatens cities into produce housing and while it presses for growth, nowhere in the state level is there an evaluation as to whether the water supply is available.
The RHNA process starts out with population projections generated by the state’s Department of Finance (DOF). These population figures are then sent to HCD which takes this data and develops regional housing (RHNA) allocations. The allocations, spread out evenly between Northern and Southern California, are distributed among 38 regional planning agencies through a RHNA Determination Letter.
Regional Level RHNA
Every region in the state has a planning agency that assigns housing allocations to the cities and communities they oversee. When regional planning agencies receive the Determination Letter, they take the regional RHNA allocations in it and break it down to city level RHNA allocations. When the HCD sent Southern California its Determination Letter showing RHNA allocations (pdf), the Southern California Association of Governments (SCAG) was assigned to provide between 409,060 and 438,030 housing units to be spread out among its 191 cities inside Los Angeles, Orange, Riverside, San Bernardino, Imperial and Ventura counties. The planning agency that represents San Diego (SANDAG) was assigned to provide 161,980 units.
To name a few other regions, if you live in Fresno its planning agency (FCOG) was assigned a RHNA allocation of 41,470 housing units. Kern’s planning agency (KCOG) was assigned a RHNA allocation of 67,675 housing units and the San Francisco Bay Area agency (ABAG) was allocated to provide for 187,990 new units. Regional planning agencies simply accept the HCD numbers at face value.
This step in the RHNA process tends to get a little ugly. Using a number of factors such as jobs, density, transportation, income levels, developable land, the regional planning agencies divide up their regional allocations into city level RHNA allocations (pdf). The regional planning agencies do not evaluate whether there is a sufficient water supply available to support housing requirements when they impose the allocations on the cities or communities. This is where the disconnect, intentional or not begins.
Some cities like Los Angeles accept these housing allocations with reckless abandon and run with it while other cities like Irvine, Palmdale, La Mirada and Pleasanton have tried unsuccessfully to challenge the regional agencies role and RHNA allocations in courts. In Irvine, the city had designated a decommissioned naval base to be the site of the “Orange County Great Park’. However, SCAG saw its potential as a huge housing development and applied a RHNA allocation of 35,660 units to the city. Pleasanton sought to limit growth with caps that were approved by voters but was sued because their housing plan they did not comply with RHNA.
City Level RHNA
The next and final step in the RHNA process is at the city level. Each city after having received their share of RHNA allocations must now incorporate it into a housing plan called the ‘Housing Element’. The Housing Element identifies the locations of all the parcels in the city that are candidates for higher density growth and is one of the eleven 'elements' that goes into a city's 'General Plan'. This is effectively the only place throughout the RHNA process where water supply comes into play, albeit indirectly.
The Housing Element does not evaluate whether there is a sufficient water supply available to support housing requirements. Instead it leaves it up to the water agencies UWMP. In the City of Los Angeles’s Housing Element, it has a section on ‘infrastructure’ where water supply is brought up. Here, the plan cites the 2010 UWMP stating “there is an adequate supply of water to serve the population growth projected through the year 2030, beyond the Housing Element planning period.”
Clearly the adequacy of the water supply in Los Angeles is demonstrably untrue, but there is no regulatory oversight anywhere in the RHNA process that will halt a project when there is no water to support it. If the water plan is based on faulty assumptions, the project will glide through to approval making it nearly impossible to create a reliable water supply.
Challenging RHNA is not possible. Courts say they have no jurisdiction. Challenging the water is one of the few areas where housing allocations can be reduced but it’s not part of the regulatory process. In “Show Me the Water Plan (E. Hanak/PPIC)”, the paper states that “planning laws (SB 221 & SB 610) rely largely on citizen enforcement rather than regulatory oversight by the state” and “that citizens can challenge the responsible local agencies in civil suits.”
Challenging water supply has been done from time to time by highly motivated groups of citizens. In “California Water Planning 2009 Vol 4 Reference Guide”(R. Waterman) this study described one such instance when a Santa Clarita group called “Santa Clarita Organization for Planning the Environment” challenged an EIR for a project involving 2,545 homes, a retail center and 42 acres of community facilities. In (SCOPE) v. county of Los Angeles, The judge agreed and the court rejected the EIR stating that the “county’s approval of the West Creek EIR is not supported by substantial evidence (of available water).”
But while its happened from time to time it’s not a process that citizens are familiar with and having citizens challenge thousands of projects a year one by one to enforce SB 221 and SB 610 (the “Show me the Water Laws”) is an undue burden. Furthering the burden, the State has legislation such as SB 1818 that allows cities and developers to squeeze more units into a parcel even when its zoned for lower densities.
Cities are not likely to challenge a developers rights to construct housing if the allocations have not been met. RHNA’s complicated process give developers the legal foundation to build new housing and sue if cities don’t cooperate, even when it is obvious to everyone that there is no water available for the project.
So where’s RHNA going to take us?
RHNA is driving up water demand. The Housing Element is updated every eight years and new RHNA allocations come out for each new refresh so what we see every eight years are just small chunks of the housing allocations which keeps the long term past and future view pretty well hidden.
Because RHNA takes its cue from DOF population projections which extend 50 years, if you want to know where RHNA is taking us look no further than the DOF P-3 projections.
These fifty year projections can swing up and down quite a bit. The 2050 projections were reduced 10 million people between the 2006/2014 and 2013/2021 but the damage is already done despite the reduced projection.
L.A.'s last RHNA allocation was 112,876 and it led to a large number of permits being approved though not all of them were necessarily built given the economic crash that occurred in 2008. However, once entitled, they stay entitled. When the economy picks up, the construction can begin. The latest RHNA allocation for Los Angeles dropped to 82,000.
The current DOF projections show the state growing to a population of 51,663,771. With this we can expect the RHNA to increase the density to increase 16% by 2030 and by 32% by 2060. A 32% increase in the City of Los Angeles suggest that water demand would increase over 938,000 Af/y if the city’s demand was held at the current 142 gallons per capita daily. That’s is about 356,000 acre-feet a year over the city’s actual average supply.
But realistically, if the RHNA process continues unrestrained by water supply, the city would have to reduce the demand to 88 gallons per capita daily to meet 2060 population targets. This is not “residential gpcd”, this is the entire city’s demand including commercial, industrial, government and residential! And what's worse.. this is just the City of LA. Imagine how disastrous and frequent droughts will be when the state hits its 16% growth target by 2030 and 32% target by 2060.
California can never have a reliable water supply unless serious reforms are made to RHNA.
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".
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.
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. Every 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.
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.
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 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
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
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
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
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.
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.
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.
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.
Would "Lose the Lawn" solve the City of Los Angeles's water problem? Throughout the state the crescendo to eliminate residential lawns has grown louder among water boards, agencies and political leaders. In Los Angeles, a partnership between the Metropolitan Water District and the DWP will even pay residents $3.75 per square foot to convert their lawns 'drought tolerant' landscape with arguable curb appeal.
"Californians should water enough to save their trees, but should let their lawns go the way of all mortal things."
Felicia Marcus - Chairwoman Water Board
So given the following extreme example, how much water could the city save if every single family home throughout the city participated in the program and killed off their lawns? And what would the long term benefit be to residents?
According to the LADWP, the 627,395 single-family residential homes it serves used an average of 144.88 HFC (hundred cubic feet) of water during the 2013/2014 water year. The same year 764,402 multi-family residential homes used an average of 96.42 HFC.
In our example we'll ignore other patterns of usage between the two types of homes (residents per household, etc.) and simply assume that the difference is entirely landscape and cut the single family home demand to 96.42 HFC just like multi-family households.
By 'Losing the Lawn' we find the city would at most reduce water demand by 69,805 Af/y or 12%. The actual reduced demand would most likely be much lower.
Benefits are only temporary
Outside of finding a way through this statewide drought there is no real long term benefit from turf removal for the residents of the City of Los Angeles.
The main beneficiary of the reduced demand would be the Metropolitan Water District since the city would be buying less water from the agency each year. If the MWD could store this water and build up reserves that would be a good thing for all. However it will most likely will be a combination of storing some of the water and selling the rest to its other member agencies.
As for the city and it's residents, L.A.'s continued growth enabled by the departments heavy reliance on paper water would quickly wipe out all of the savings within ten years. The city's 2010 UWMP projects the demand will increase by 60,000 Af/y in 2025 and by 86,000 Af/y in 2030. Nearly all of this increase will be multi-family residential so effectively residents would be trading their homes lawn for density.
Since we can expect that the city's real water supply will remain flat, growth will assure that the city's future supply would be as tedious after the lawns are gone as they are today.
The City of Los Angeles water plans in the past have projected significant amounts of water that later never came. These large sums of water have been used to approve small and large projects going back to 1990.
When projects are reviewed by city planners, the figures cited in the city's water plans are supposed to assure the community that there is sufficient water for the project over the next 20 to 25 years after they are approved and that the project will not pose a burden to the city's water supply during that period.
Over a 24 year period, this missing water would be equivalent to 4.35 million acre feet which is slightly more than a full years worth of California Aqueduct water at full allocation.