The Owens Valley Committee
Promoting citizen involvement in water and land management 

Groundwater pumping plan 2001-2002

Comment Regarding the Proposed 2001-2002 Annual Pumping Plan submitted by the Bristlecone Chapter of the California Native Plant Society and The Owens Valley Committee

The goal of the Inyo-LA Water Agreement is to manage groundwater resources to avoid significant environmental impacts which cannot be adequately mitigated while providing a reliable supply of water to Los Angeles.

For the 2001-2002 runoff year Inyo County and LADWP have already agreed to pumping levels essentially equivalent to those of 2000-2001 in spite of the fact that recharge has been below normal for the second year in a row. Because of this there is no question that the goal of maintaining a "reliable" water supply to LA is being met.

We do not believe, however, that either Inyo County or DWP are adequately fulfilling their obligation to manage pumping to avoid impacts to native vegetation.

The Inyo County Water Department's data show that well-field vegetation in the 10 years since the Water Agreement was negotiated has shown a pattern of decline followed by recovery. By Inyo County's criteria vegetation in most parcels -- but not all -- has now recovered to the levels mapped in the 1984-87 baseline years. LADWP argues that recovery of vegetation in the disputed wellfields is "close enough" to baseline and that in attempting to limit pumping in the disputed wellfields Inyo County is trying to hold DWP to an excessively high standard of recovery for vegetation and water tables.

Our first comment is that the county's standard of recovery, rather than being excessively high, is actually too low. According to annual reports from the Inyo County Water Department the cover of perennial vegetation in un-pumped parcels increased significantly over baseline levels in the same period of time that cover in well-fields declined. Were Inyo County and LADWP seriously attempting to avoid groundwater pumping impacts they would agree that cover in well-fields should equal cover in control areas. If pumping were managed to avoid significant impacts, there would be no significant difference in vegetative cover between pumped and un-pumped areas of similar vegetation type.

See info on the web about


Under construction:

Neither Inyo County nor LA, however, has proposed using this standard for the Drought Recovery Policy or anything else. Inyo County is, instead, settling for the lower standard of restoration of vegetation to 1984-1987 baseline conditions while DWP is attempting to evade even this low standard.

Our second comment is that measurement of total perennial cover -- one of the county's main techniques for measuring pumping impacts with regard to the Drought Recovery Policy -- is a crude tool to measure ecological change. Measurement of total perennial cover does not describe species composition or community structure. For example, native grasses in a meadow may be weakened by lowered water tables and subsequently be invaded by noxious weeds. If the total perennial cover of the weed-infested meadow, however, subsequently increases to reach the baseline cover of the original grass-dominated meadow, it appears both Inyo County and DWP will agree that the parcel has "recovered", release it from the constraints of the Drought Recovery Policy and allow the water table to be lowered again. By using this crude technique to measure change and recovery of vegetation in our opinion neither Inyo nor LADWP are adequately discharging their obligations to manage pumping to avoid significant environmental impacts.

For these reasons we believe that the 72,300 acre.feet. of pumping proposed by Inyo County is, if anything, excessive and should be the maximum -- rather than the minimum -- permissible volume of pumping for 2001-2002.

Finally, we would like to point out that Inyo County's attempt to implement the Drought Recovery Policy, even if imperfect, represents a good faith effort. The County has produced reports every year since 1999 describing in detail its application of the Drought Recovery Policy to every parcel. Prior to 1999 vegetation conditions were routinely reported to the Technical Group on at least an annual basis. LADWP, however, has never bothered to comment on these reports at Technical Group meetings nor has it even once raised the issue of how the Drought Recovery Policy might be implemented.

We object to DWP's submission of criticisms of the county's implementation of the Drought Recovery Policy to the arbitrator when DWP has chosen not to raise these criticisms in public at Technical Group meetings where they would be subject to critical scrutiny. The Water Agreement makes it clear that the Technical Group is the appropriate forum to resolve technical issues and we do not think DWP should be allowed to bypass it. For this reason we respectfully request that DWP's document of June 1, 2001 titled "Reply to Inyo County Water Department Comments Dated May 18, 2001 and Transmittal Letter Dated May 22, 2001" be withdrawn from consideration by the arbitrator.

Thank you for considering these comments.

Mike Prather, President, Owens Valley Committee

Daniel Pritchett, Conservation Chair, Bristlecone Chapter,
California Native Plant Society