4/28/2002 LADWP's 2002 pumping plan: spin-doctoring and incomplete analysis
The Los Angeles Department of Water and Power (LADWP) released its proposed 2002 pumping plan recently. The plan calls for a slight increase over what LADWP proposed last year in spite of the fact that estimates for total runoff this year are even lower than last year's below-average total. In the cover letter accompanying the proposed pumping plan, LADWP's Gene Coufal presented a rationale for the proposed pumping. He wrote that, "Due to the success of the Drought Recovery Policy and associated ten consecutive years of low pumping, high water tables persist throughout the valley." This sentence is an excellent example of spin-doctoring and it is worthy of detailed examination.

First, note the adjective "low"describing past pumping. "Low" relative to what? LADWP's average annual pumping over the past 10 years has been approximately 74,500 acre feet. This is enough water to flood an area the size of Owens Lake one foot deep in water every year. Elsewhere in the Great Basin controversy has occurred over pumping volumes an order of magnitude smaller than this. Only LADWP would have the arrogance to refer to 75,000 acre feet of pumping as "low."

Next, note the adjective "high" describing water tables. This also is completely subjective. In this case, however, there is a biological standard which can be applied. The presence of groundwater-dependent vegetation is a good indicator of the long-term "average" water table depth over periods which may date back centuries. Groundwater-dependent plants could not exist if, in the long run, the water table stayed at a depth which could not be reached by their roots. According to data from the Inyo County Water Department (ICWD), water tables under only about half the well field parcels sampled have recovered to the rooting zone of native vegetation When water tables are considered with regard to this biological standard, what LADWP refers to as "high" turns out to be "below the long-term average" for about half the area of concern and "barely up to the long-term average" in the other half.

Finally, note the verb "persist." This word connotes a degree of longevity. It implies these "high" water table conditions have been around for a long time. According to ICWD data,in those areas where water tables have actually recovered to the rooting zone the recovery has only occurred in the past few years. This condition is not accurately described in LADWP's use of the word "persist".

Having presented a self-serving and biologically meaningless description of current water table conditions, LADWP then admits, "The limited pumping outlined below will likely lead to temporary decline in parts of most well fields." How long is "temporary"? Nowhere is the word "temporary" defined. How great will the decline be? Nowhere is the amount of the decline quantified. Under which parcels will the decline occur? Nowhere are the "temporarily" affected parcels identified.

Without further information on the affected parcels (including future management plans) how can the pumping program be reasonably evaluated at all? The vegetation protection goals of the Water Agreement are defined in terms of units of similar vegetation known as parcels not in terms of the large areas of varied habitats known as well fields. LADWP presents its pumping plan primarily at the scale of the well field. If the pumping program is to be taken seriously there must be a parcel-based analysis of proposed pumping impacts.

Quite apart from the problem of the absence of adequate data upon which to make an evaluation, the Drought Recovery Policy (DRP) alone provides strong grounds for Inyo County to insist on changes in this proposed pumping program. 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 (italics added)." The DRP also mandates "conservative management". In terms of wellfield vegetation parcels the goal of the DRP has been only partly attained. Nevertheless LADWP is again proposing to lower water tables and is not stating how much lower or when they will finally be allowed to recover to the rooting zone of groundwater-dependent vegetation. This is not "conservative" management.

It is up to our county supervisors to insist that the DRP be enforced and that proposed pumping be consistent with both goals of the Water Agreement: 1) insuring a reliable water supply to LA and, 2) avoiding significant environmental impacts in the Owens Valley. Examination of pumping records shows the first goal is being attained. Examination of well field vegetation shows the second goal is not. If the 2002 pumping plan is accepted as written, the recovery of water tables and vegetation will be postponed yet another year. This will increase the likelihood that the limits of drought-tolerance of even our hardy native plants will be exceeded and that recovery from the over-pumping and drought of the late 1980's will never occur.

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