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.
In the most recent Water Board Water Conservation Report showing the state's June 2015 conservation, LADWP has been revising population figures presumably to keep the Residential gallons per capita daily (R-GPCD) level from getting out of control. They are now estimating monthly population growth and using each months figures to calculate residential water use.
I was surprised they kept using the 3,935,257 figure from month to month since leaving the population number where it was would have artificially raised the R-GPCD while population and demand increased. The screen shot from the report shows the department's estimates that the city has grown by 55,089 residents in last twelve months (or roughly 19,674 new units1 constructed) while it has been losing water supply.
RHNA forces cities to identify properties that are suitable for development for the number of units they are allocated for. Despite the 7 year long water deficit the city has been fighting, the increasing population numbers that the LADWP is providing is a result of the California's RHNA requirement. If a developer wants to build on a property identified in the Housing Element (a RHNA requirement), the city can't say no by state law unless the UWMP or WSA is successfully challenged.
Any gains being made by residents to recover from the drought (turf removal, limiting landscaping watering days, low flow toilets, high efficiency washers, etc.) to increase storage levels and reserves are simply wiped out the state and city planning process.
12013-2021 Los Angeles Housing Element reports average of 2.8 inhabitants per dwelling unit.
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.
LADWP water plans are generally more about perception than results and 'Purple Pipe' is certainly the poster child proving that.
Purple pipe is used to distribute non-potable recycled water and is often presented as one of the departments cornerstone resources to meeting the city's water supply demand since it frees up potable water that would have been used for irrigation or industrial use. Thumb through many of the DWP’s presentations and you'll find impressive glossy photos of purple pipe that suggest that it's been making big contributions to increasing the City of Los Angeles water supply. Even the Mayor and thecity’s neighborhoodcouncilsarelulledintothisgroupthink.
However when perception meets gritty reality, purple pipes contribution to the city's water supply is simply underwhelming and not deserving of so much attention. Past LADWP water plans told us recycled water was supposed to deliver be delivering ~30,000 Af/y to the city by 2015. But instead the city's been getting an average of only 7,600 Af/y.
There are several reasons for this shortfall, the biggest being the same reason the city isn’t able to effectively replace its aging water mains. The immense cost of such an effort and the disruptive nature of digging up thousands of miles of city streets in a city that is already built out and paved over is prohibitive. The department says it would take 300 years to replace its crumbling water mains. Building a distribution network of purple pipe runs into the same problems of cost and disruption.
This leaves the department to choose routes where it can get the most bang for its buck. Generally this means it has to be a customer who can use lots of recycled water and is relatively near by the filtering plant. In the city's west side for example, only a few customers like LAX, Westchester Golf Course, Loyola Marymount and Playa Vista fall into that category.
Sure it would be nice to have purple pipe running alongside the city's water mains that finally connects up to every large commercial and residential complex but that's not going to happen.
The other reason for the lack of progress is that recycled water is primarily for irrigation and industrial use. In the 1980's the city's industrial use was ~30,000 Af/y but overtime this has fallen to an average of just 19,000 Af/y. The rest would go to city parks, golf courses and new commercial/residential developments that are close enough to filtering plants that makes it economically viable to tear out a few streets and lay new purple pipe.
This is not a growing customer segment that justifies the departments claim that it will increase recycled water to 42,000 Af/y by 2025 and 59,000 Af/y by 2035.
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.
Construction projects going through the city permit process are required to cite how much water demand they will impose on the city's water supply and whether the city has surplus water supplies to accommodate the project.
This information is provided in the EIR (Environmental Impact Report) which is part of the permit package for the project. The EIR's have a section on 'Utilities' stating where this surplus water will come from. As evidence of sufficient surplus water, the EIR's refer you to the city's current UWMP as evidence. The UWMP also describes how it will meet demand should there be a shortages of city owned water. When water shortages occur the city's water plans state that they have access to MWD supplies that will meet the city's level of demand.
The chart below shows us that despite the UWMP's guarantee that the Metropolitan Water District will be able to provide sufficient water supply in dry years, the DWP has not been able to meet that guarantee since MWD supplies have come up short of the projections every year since 1990.
The deficit the city finds itself in is a result of this gap. Because this has been allowed to occur for twenty five years and never corrected in each subsequent UWMP, we have to assume that these statements in the UWMP assuring that MWD will meet demand are mainly intended to facilitate approvals and nothing more. As such, it is a planned deficit.
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.
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.
One prominent member of the City of Los Angeles's 'paper water' portfolio is recycled water. Like L.A.'s groundwater supply, its Urban Water Management Plans between 1990 and 2005 had projected rapidly growing recycled water supplies that would never be realized.
The chart at the right plots the huge gap between the actual recycled water 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.
For example when we look at the 1990 UWMP projections, the city expected that its program for recycle water supply would triple within 5 years and eventually provide the city with over 30,000 af/y in 2000. This never happened.
When the following 1995 UWMP came out it didn't begin where the 1990 plan left off. If fact it would cite less water in 2000 than the '90 plan which suggests that the effort to increase recycled water was making no progress.
Of course paper water being what it is, that plan would still suggest (with no factual basis) that recycled water would still triple, this time within 10 years and then more than quadruple to 38,000 af/y within 15 years.
The next 2000 UWMP was no different, it would also start off with less water than the preceding plans had projected and then nearly quadruple within 15 years with supplies approaching 30,000 af/y.
Little progress meeting past targets
The actual supply between 1985 and 2010 hasn't been nearly so grand as the city's expectations and glossy presentations that suggested that recycled water would help the city meet its needs. The actual recycle water supply between 1995 and 2005 was so tiny at just 1,748 af/y and was barely perceptible on a chart.
Between 2006 and 2014 the city's recycle supply would grow to just 6,410 af/y which is far below any of the past UWMP projections that ranged from 19,950 af/y to 38,000 af/y and light years behind the projected 850% increase now cited in the 2010 UWMP to 59,000 af/y by 2035.
This huge gap between 'projected or anticipated supply' and 'actual supply' is an unfortunate characteristic of the city's water supply we would call paper water. 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 gap has only widen between 1990 and 2015 and given the city's history of meeting its projections, I don't have much faith that it will meet the 59,000 af/y target it has set for 2035. If it could have met the much lower targets it had set in earlier plans, it would have done so by now. However the obstacles such as trying to roll out a citywide network of purple pipe were just to huge to overcome.