One of the many permitting hoops that the Delta Conveyance Project must jump through on the road to construction should it be approved is the determination of consistency with the applicable policies in the Delta Stewardship Council’s Delta Plan, most notably policy WRP 1, which requires demonstration of reduced reliance on the Delta. The controversial project is all but certain to be appealed, so with hundreds of water agencies poised to benefit from the project, just how can reduced reliance be demonstrated?
At the November meeting of the Delta Stewardship Council, Katherine Marquez from DWR and Jennifer Nevills from Metropolitan Water District summarized recent work completed to assemble the data that was included 2020 urban and agricultural water management plans prepared by numerous water suppliers who would receive water from the Delta Conveyance Project.
First, a bit of background …
The Delta Reform Act of 2009 established the coequal goals of reliable water supplies and Delta ecosystem restoration and charged the Delta Stewardship Council with developing the Delta Plan to achieve the coequal goals and protect the Delta as an evolving place. The Delta Plan includes 14 regulatory policies and 95 recommendations that address current and predicted challenges related to the Delta’s ecology, flood management, land use, water quality, and water supply reliability.
The legislation also established the covered action process for demonstrating consistency with the Delta Plan’s regulatory policies. A covered action is a project that a state or local agency is pursuing that exists, in whole or in part, in the Delta and has the potential to significantly affect the coequal goals or state flood control. A covered action demonstrates consistency with the Delta Plan by submitting a certification of consistency that includes detailed findings of consistency with the applicable policies. It is developed by the agency pursuing the covered action themselves.
The Delta Stewardship Council does not approve the consistency determination; however, any interested party can appeal a consistency determination, which will ultimately result in a public hearing. The Department of Water Resources submitted a consistency determination for the California Water Fix, predecessor to the Delta Conveyance Project. The consistency determination was appealed; DWR withdrew the consistency determination after the staff report and comments at the public hearing made it clear that the appeal would be upheld.
And given the contentiousness of the Delta Conveyance Project, an appeal is virtually certain.
Gathering the data
So, how will water suppliers demonstrate reduced reliance on the Delta? The policy is looking to the urban and agricultural water management plans to provide that information.
Urban water suppliers that serve more than 3000 service connections or more than 3000 acre-feet per year of water are required to prepare an urban water management plan every five years. The plans are required to demonstrate the supplier’s water supply capability under different future scenarios, such as normal, single dry, or multiple dry year conditions. DWR reviews each supplier’s plan to ensure the plan meets the requirements. The 2020 urban water management plans were submitted to DWR in mid-2021; the 2025 plans will be submitted to DWR in mid-2026.
Agricultural water management plans are required from ag suppliers who serve more than 25,000 acres, excluding recycled water, but the reporting requirements are somewhat different. Ag water management plans must include an inventory of efficient water management practices, including measurement of water delivered to customers with a sufficient level of accuracy and adopting pricing structures based at least in part on the quantity of water delivered. There are an additional 14 measures that water suppliers must certify that they are already implementing, in the progress of implementing, or technically not able to implement. Those include automating canal control structures or facilitating customer pump testing and evaluation, which may or may not apply to the given agency.
There are some caveats with using data from the plans. First, the plans provide data on past, current, and future water supplies and demands, as well as water use efficiency and efficient water management practices to demonstrate capability under different scenarios. That is somewhat contrary to showing reduced reliance, so the data must be used carefully. Secondly, there can be several layers of water suppliers between the Delta and the agency completing the urban plan, particularly Southern California. Lastly, Metropolitan member agencies fund regional water projects through rates, so it can become very complicated to determine exactly what water is going where.
Ms. Marquez and Ms. Nevills were part of a collaborative process involving folks from the Delta Stewardship Council, DWR, and public water agencies who developed a methodology that was included in the 2020 urban and agricultural management plan guidebooks. Since including this information in ag and urban water management plans is optional, DWR’s Delta Conveyance office sent letters to State Water Project contractors encouraging them to include this data in their 2020 plans, both to support the record for a potential future certification for the Delta Conveyance Project and to help them with any potential other future covered actions they may participate in.
Analysis: Are State Water Project water agencies reducing reliance?
They then surveyed the submitted plans from suppliers, and they found that out of 245 urban water suppliers, 238 of them had completed an urban water management plan. Of those 238, 52 demonstrated reduced reliance on the Delta specifically following the guidelines in the guidebook; 119 showed regional self-reliance improvements rather than changes in Delta reliance; and 67 fell into other designations that needed additional work.
Out of 11 agricultural water suppliers, 10 of them had completed a plan as of spring. Seven showed reduced reliance, and three fell into other designations, where they didn’t necessarily follow the approach that was outlined but provided other data showing reductions in use from historical or future expected reductions in use or reductions in applied water per unit of production.
So, in summary, out of the 238 urban water management plans reviewed, 225 demonstrated a pathway to reduced reliance or increased regional self-reliance, and out of the ten ag plans evaluated, nine demonstrated a reduced reliance pathway.
They also noted that overall urban and ag use is expected to continue to decline in total in the future. From the baseline to 2030, urban water use is expected to fall by another 15% over that period. Agricultural use is expected to reduce by about 19% and 2030 and 27% by 2070.
Ms. Marquez noted that their analysis collected data previously not available in the format identified in the policy. Since it is optional, there is no guarantee that it will be in future plans. And since the policy specifically seeks to collect the data on an individual supplier basis, that may not fully capture all the contributions that an individual supplier is making towards reduced reliance or improving regional self-reliance because of the contributions they might be making on a regional or statewide basis.
She closed by noting that the data and techniques developed for this process are now available to support any other future covered action that might trigger this policy, and the data collected could support several Delta Plan performance measures related to urban and ag water management plans.
