See info on the web about
(Note: See Action Item # 2 under "Take
Action" for more on this issue)
The Drought Recovery Policy (DRP) is an overlay on the Water Agreement.
By instituting controls on groundwater pumping beyond those specified in the
on/off procedures in the Green Book, the DRP provides insurance that the
vegetation protection goals of the Water Agreement will be met.
The DRP has assumed great importance because the Inyo County Water
Department (ICWD) has shown that the current Green Book on/off procedures
are flawed. Until the Technical Group can agree upon improved on/off criteria,
the DRP is what prevents excessive groundwater pumping by the Los Angeles
Department of Water and Power (LADWP) in its annual pumping programs.
At the Technical Group meeting of 12/10/01 LADWP's consultant,
Montgomery Watson Harza (MWH), unveiled a new interpretation
of the DRP. MWH's interpretation of the DRP
is based on two main premises: 1) the sole factors to be considered
in determining the applicability of the DRP are soil moisture and
depth-to-water-table-- the condition of native vegetation is
irrelevant and 2) the scale of analysis in applying the DRP is
the entire wellfield, rather than parcels within wellfields. Both
premises are contradicted by language in the DRP.
|photo by Ceal Klingler
The goal of the DRP is that "soil water
in the rooting zone recover to a degree sufficient so
that the vegetation protection goals of the [Water] Agreement are achieved."
To attain this goal "...soil water, water tables and vegetation conditions
will be monitored by the Technical Group to ensure the goal is being
achieved."[all italics added] Both the goal and means of implementation
of the DRP explicitly require consideration of condition of native vegetation.
The use of the wellfield as the unit of analysis (LADWP's consultant's second premise)
is inappropriate because vegetation is not uniform within wellfields. LADWP
delineated parcels of relatively homogeneous vegetation within each wellfield
in the 1980s, and the parcels have been used as the basis of vegetation monitoring
and management under the Water Agreement ever since. It follows from the DRP's
explicit emphasis on the condition of native vegetation that the
vegetation parcel-- rather than the wellfield-- should be the unit of analysis.
A final point is that MWH has decided to equate the "substantial recovery"
of soil moisture called for in the second paragraph of the DRP with 80% of
the water table drawdown. This equation of "substantial" with "80%" is completely
arbitrary and based on no ecological data whatsoever. More important, the 80%
criterion disregards the explicit goal of the DRP (cited above) of water table
recovery in the rooting zone of native vegetation.
It is no surprise that when MWH applied this interpretation of the DRP,
it concluded that "termination of the DRP is appropriate."
ICWD, on the other hand, has followed the explicit requirements of the DRP
by analyzing soil water, water table, and vegetation conditions of parcels
throughout the valley every year for the past three years. It has repeatedly
found that parcels farthest from pumps have met the goal of the DRP while those
closest to pumps often have not, and that termination of the DRP for many parcels
is not appropriate. ICWD's most recent DRP status report (as well as the text of
the DRP itself) is available on its website at www.inyowater.org. Although ICWD's
findings have been presented to the Technical Group each year LADWP has never offered
any comments or expressed any objection to them.
Both Inyo County and LADWP made major concessions in the years of negotiations
which lead to the Water Agreement and MOU. LADWP's consultant's interpretation of the DRP would
require Inyo County to make further concessions which will place native vegetation
in even greater jeopardy than it is in already. The Owens Valley Committee believes
the interpretation of the DRP used by the ICWD and presented to the Technical Group
with no objection by LADWP follows both the letter and the spirit of the DRP.
proposed new interpretation is unnecessary and contrary to the stated goals and
implementation methods of the