Water Considerations for Cities - California Grand Jury Reports

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actually shows a slightly increasing trend. Historical data for the Northern Sierra Precipitation 8-station Index - an aggregate measurement of rainfall and snowpack water content - reveals that since record keeping began in this critical region, the 20-year moving average precipitation level has increased by over 21% from 44.1 inches in 1940 to 53.5 inches in 2017 (see attached Exhibit 7 from Calleguas Municipal Water District (Calleguas)). Snowpack: Historical data for snowpack in the Feather River Watershed shows

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a slightly decreasing trend. The April 1 20-year moving average snowpack water content for nine snow courses in the Feather River Watershed for which annual data has been consistently recorded since 1930 has remained relatively steady. The most recent preceding 40-year average (27.8 inches) is 92 percent of the initial preceding 40-year average of 1969 (30.2 inches). The most recent 20-year moving average (27.3) is within one inch of the initial 20-year moving average of 1949 (28 inches), (see attached Exhibit 7 from Calleguas). We acknowledge that it is largely anticipated by climatologists that the Sierra snowpack is likely to diminish over time as temperatures are expected to rise. However, the State Water Project (SWP) and those agencies that receive water therefrom have the ability to deliver large quantities of water falling as rain into surface reservoirs and groundwater basins statewide. For example, over the winter months of 2017, SWP export pumps operated at full capacity for many weeks for the first time in nearly one- quarter century due to heavy rainfall - not snowfall - in the northern Sierra. UWCD Response to C-01 partially disagree. UWMPs are based on the best information available at the time they are prepared. Projections of supplies and demands are based on historical trends, future availability of existing or proposed sources of supply, environmental changes, regulatory restrictions, per capita water use reductions, and other factors. UWMPs look forward 25 years, but are revised every five years and adjusted as new information becomes available. The source of water for the O-H system is groundwater. This groundwater source is recharged by precipitation and is largely influenced by surface water from the Santa Clara River that is diverted at UWCD's Freeman Diversion and spread in groundwater recharge basins for percolation into the underlying aquifers. The O-H system is located in the Oxnard Plain which has a mild Mediterranean style climate. The annual average precipitation for the area is reported to be 15.64 inches, 250 North Ventura Road • Port Hueneme, CA 93041 • Phone (805) 986-6510 • Fax (805) 986-6581 www.cityofporthueneme.org which predominately occurs in winter months (November through March)1. Precipitation is more often below the annual average, with extreme precipitation years skewing the average higher. The annual average precipitation has not changed significantly according to records that have been kept since the 1880s, but there may be some evidence of greater peak precipitation years (both high and low) starting in the 1930s and becoming more frequent in the 1970s to present. Error! Reference source not found. best illustrates the high variability in precipitation by year. Flows from intense storms that occur in short periods of time are more difficult to capture at surface water diversion facilities, percolate and store in underlying groundwater aquifers. In the last decade, UWCD has acquired additional groundwater recharge basins for the purpose of percolating additional surface water diversions and potentially surface water with higher turbidity. However, environmental regulations intended to protect endangered fish habitat and migration restrict the time period that surface water that can be diverted. Spatially Averaged Annual Water-Year Rainfall on Mound, Oxnard Plain, and Pleasant Valley Sub-Basins vs. Pacific Decadal Oscillation Index 5 40

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C-01: Cities' water plans are based on historic water availability patterns which may no longer be applicable. Over the last 100 years, water availability from precipitation has been trending downward and may never return to water was considered average. CMWD Response to C-01 partially disagree. Urban Water Management Plans (UWMPs) are based on the best information available at the time they are prepared. Projections of supplies and demands are based on historical trends, future availability of existing or proposed sources of supply, 250 North Ventura Road • Port Hueneme, CA 93041 • Phone (805) 986-6510 • Fax (805) 986-6581 www.cityofporthueneme.org

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environmental changes, regulatory restrictions, per capita water use reductions, and other factors. UWMPs look forward 25 years, but are revised every five years and adjusted as new information becomes available. The Feather River Watershed in the northern Sierra serves as the headwaters for the California State Water Project, which is the source of imported water for the City of Port Hueneme. Precipitation: Historical data on precipitation in the Feather River Watershed . actually shows a slightly increasing trend. Historical data for the Northern Sierra Precipitation 8-station Index - an aggregate measurement of rainfall and snowpack water content - reveals that since record keeping began in this critical region, the 20-year moving average precipitation level has increased by over 21% from 44.1 inches in 1940 to 53.5 inches in 2017 (see attached Exhibit 7 from Calleguas Municipal Water District (Calleguas)).

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Snowpack: Historical data for snowpack in the Feather River Watershed shows

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which predominately occurs in winter months (November through March)1. Precipitation is more often below the annual average, with extreme precipitation years skewing the average higher. The annual average precipitation has not changed significantly according to records that have been kept since the 1880s, but there may be some evidence of greater peak precipitation years (both high and low) starting in the 1930s and becoming more frequent in the 1970s to present. Error! Reference source not found. best illustrates the high variability in precipitation by year. Flows from intense storms that occur in short periods of time are more difficult to capture at surface water diversion facilities, percolate and store in underlying groundwater aquifers. In the last decade, UWCD has acquired additional groundwater recharge basins for the purpose of percolating additional surface water diversions and potentially surface water with higher turbidity. However, environmental regulations intended to protect endangered fish habitat and migration restrict the time period that surface water that can be diverted. Spatially Averaged Annual Water-Year Rainfall on Mound, Oxnard Plain, and Pleasant Valley Sub-Basins vs. Pacific Decadal Oscillation Index 40

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Spatially Averaged Annual Rainfall (in)

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10-yr Moving Avg Rainfall (in/yr)

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PDO Annual Average by Water Year

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inverseWYavgSOI Pacific Decadal Oscillation Index 10 per. Mov. Avg. (Spatially Averaged Annual Rainfall (in)) 30 10 per. Mov. Avg. (PDO Annual Average by Water Year) Annual Rainfall (inches) 25 20 0 15 10 -2 5 -3 0 2015 2005 1985 1995 1925 1935 1975 5561 1965 1945 1885 1905 1915 1875 1895 Water Year C-02 Cities' plans address the minimum, state-required, three-year drought scenarios. None of the UWMPs address a long term drought, even though the current drought has lasted over five years. CMWD Response to C-02 partially disagree. The 2015 UWMPs were prepared in accordance with the state-required, three-year drought scenarios, and it is expected that by the time the next UWMPs are prepared, Climate Data for Oxnard California, www.usclimatedata.com/climate/oxnard/california/united-states/usca0819 (accessed 21 July 2017). 250 North Ventura Road • Port Hueneme, CA 93041 • Phone (805) 986-6510 • Fax (805) 986-6581 www.cityofporthueneme.org

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the state will have implemented a requirement for evaluation of five-year drought scenarios, with which the City of Port Hueneme will comply. City of Port Hueneme pays Metropolitan Water District of Southern California (Metropolitan) through water rates to invest in storage and supply diversification projects and programs in preparation for droughts. In the quarter century leading up to the recent drought, Metropolitan built up a diverse portfolio of such supplies. They paid to line canals in the Imperial Valley and stored the conserved water in Lake Mead. They built Diamond Valley Lake in Hemet and filled it with water, more than doubling their storage capacity in Southern California. They paid to install aquifer storage and recovery wells in aquifers in the Central Valley and stored water in a groundwater bank. They purchased land and entered into fallowing agreements with farmers near Blythe so that they could use those farmers' water in urban Southern California during dry years. During the recent drought, Metropolitan was able to deliver water from all of these supplies. In addition, they reached out to water agencies and agricultural entities throughout the state to buy excess (so-called "transfer") water and move it to Southern California to preserve as much water in storage as possible. As a result of these varied supply reliability actions and programs, City of Port Hueneme weathered the recent five-year drought with minimal effect on its residents and businesses. UWCD Response to C-02 partially disagree. The 2015 UWMPs were prepared in accordance with the state-required, three-year drought scenarios, and it is expected that by the time the next UWMPs are prepared, the state will have implemented a requirement for evaluation of five-year drought scenarios, with which UWCD will comply. The O-H Pipeline has weathered the current five year drought due to flexibility in its well field system. The El Rio Groundwater Recharge Facility's wellfield consists of twelve (12) groundwater extraction wells constructed at different depths. Nine (9) of these wells are shallow and extract water from the Upper Aquifer System (UAS). The UAS is easily recharged by precipitation and surface water diversions. Three (3) of these wells are deep and extract water from the Lower Aquifer System (LAS). The LAS is considered a confined aquifer system and is slower to recharge. During drought years, groundwater levels decline and nitrate concentrations increase in the UAS. Drinking water regulations do not permit nitrate (NO3) concentrations to exceed 10 milligrams per liter (NO3 as Nitrogen). The LAS wells have low levels of nitrate concentrations and can provide a reliable source of water to be blended with available UAS well water during periods of extended drought. However, the LAS wells also contain high concentrations of naturally occurring iron and manganese, which affect water aesthetics (color, odor and taste). UWCD has plans to construct an iron and manganese treatment facility to address these concerns. C-03 Long term city plans are based on the optimistic view that there will be as much water available in 2035 and 2040, as there was in 2010. Additional future water 250 North Ventura Road • Port Hueneme, CA 93041 • Phone (805) 986-6510 • Fax (805) 986-6581 www.cityofporthueneme.org

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resources are not well-defined other than being described as imported water or coming from recycling and conservation efforts. CMWD Response to C-03 disagree. Based on Metropolitan's multiple dry-year supply forecast through 2040, developed as part of its 2015 UWMP update process (see attached Exhibit 4 from Calleguas), Metropolitan anticipates having more than sufficient supplies available to meet Calleguas purveyors' imported water demands as described in Calleguas' 2015 UWMP. In addition, because of state regulatory actions to "make water conservation a way of life", the demand for water in the future will likely be lower than anticipated when the UWMP's were prepared in 2015, further improving the region's ability to sustain lengthy shortages. In addition, UWMPs will be updated four times between now and 2040, and will be adjusted each time according to the best available information. The City of Port Hueneme's 2015 UWMP does describe specific future water resources and additional projects such as a third stage reverse osmosis system to increase the efficiency of the Brackish Water Reclamation Demonstration Facility. UWCD Response to C-03 disagree. The available water supply for the Oxnard-Hueneme Pipeline is dependent on groundwater extraction allocations that are regulated and established by the Fox Canyon Groundwater Management Agency (FCGMA). In 2002, the FCGMA passed Ordinance No. 8 which reduced groundwater extraction allocations to 75% of the historical baseline extraction level reported in 1985 to 1989. In 2014, California Governor Edmund Gerald Brown, Jr. proclaimed a state of emergency due to drought conditions and also signed into law the Sustainable Groundwater Management Act (SGMA). At the same time, the FCGMA issued Emergency Ordinance E, establishing Temporary Extraction Allocations (TEA), effectively superseding Ordinance No. 8. By January 1, 2016, the TEA reduction reached 20%, which is based on historical groundwater extractions for Calendar Years 2003 through 2012 (already reduced by Ordinance No. 8). Currently, the TEA groundwater extraction allocation for the O-H Pipeline water supply is 11,757.40 acre-feet per year. UWCD anticipates being able to provide water supply for the O-H Pipeline up to the groundwater extraction allocation in the years to come. SGMA legislation requires that the FCGMA prepare and implement a Groundwater Sustainability Plan (GSP) that will employ best management practices for the sustainable management of groundwater. The FCGMA must adopt and implement the GSP not later than January 31, 2020. It is not currently understood how the GSP might impact the existing groundwater extraction allocation, but it is possible that the allocation will be reduced. Water demand for the O-H Pipeline system has been tempered by state and local regulatory actions to "make water conservation a way of life." The largest customers, the Cities of Oxnard and Port Hueneme, have both adopted ordinances that establish mandatory water conservation practices. Both Cities' baseline water use per capita has 250 North Ventura Road • Port Hueneme, CA 93041 • Phone (805) 986-6510 • Fax (805) 986-6581 www.cityofporthueneme.org

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dropped below previously established targets, suggesting that water conservation practices have helped to curtail water demand. The water use per capita could continue to decrease in the future further improving the region's ability to sustain lengthy water supply shortages. UWCD is working towards future water resources to help reduce overdraft and seawater intrusion in the Oxnard Plain. These projects may include State Water Project importation (when available) for direct use or groundwater recharge, recycled water deliveries for direct use and groundwater recharge, and brackish water treatment of saline groundwater. These projects are in conceptual-level planning stages and will likely be better defined in future UWMP updates, which will be updated four times between now and 2040. C-04 Current and future ratepayers will bear the burden of the cost of building water purification facilities, desalination plants, desalters, recycling plants, additional pipelines, and storage facilities needed to ensure there is an adequate water supply system in the future. CMWD Response to C-04 agree. UWCD Response to C-04 agree. C-05 Since many cities in the County rely on Metropolitan's wholesale water, Cities should base UWMPs on the wholesalers' prediction that retail water demand will outstrip total reliable resources by 2040. CMWD Response to C-05 disagree. This comment appears to be based on a misinterpretation of the "Do Nothing" case in Metropolitan's 2015 Integrated Resources Plan Update (IRP) (see attached Exhibit 3 from Calleguas). This scenario provides an assessment of what future water reliability would be with no additional actions or investments in water supply or demand management. The "Do Nothing" analysis determines whether additional developments that help to balance supplies and demands are needed to ensure reliability into the future. As stated on page 6.0 of the IRP, "doing nothing is not an option." This scenario simply serves as a reference point for long-term resource planning purposes. In fact a multitude of supply and demand management projects and programs are being or will be implemented, with varying degrees of certainty, to reliably meet future demands. UWCD Response to C-05 no response. (Relates to Metropolitan's wholesale water) C-06 The UWMPs use different sources for analyzing past and future populations. The inconsistency makes it difficult to compare plans, especially when cities have multiple retail water providers. Some UWMPs even use different population sources within the same report. CMWD and UWCD Response to C-06 agree. 250 North Ventura Road • Port Hueneme, CA 93041 • Phone (805) 986-6510 • Fax (805) 986-6581 www.cityofporthueneme.org

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Population projections are done by local water agencies in coordination with cities with consideration of proposed development projects and patterns. Some of these local water agency boundaries match city boundaries, but more often they do not. So each population projection must be customized to the area. As provided in Final 2015 UWMP Guidebook for Urban Water Suppliers, Page 3-7: "The CWC[California Water Code] does not require a specific methodology for projecting future populations, but it does require that the estimates of future population be based upon data from State, regional, or local service agency population projections. Include the source(s) used to estimate the population projections (2020, 2025 etc...)." C-07 Cities' water plans do not appear to address catastrophic failures or interruptions within the system, such as:

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Infrastructure failures (dams)

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Environmental disasters (oil or chemical spills)

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CMWD Response to C-07 disagree. Plans to address water supply emergencies and groundwater quality exist, but are done outside the UWMP process. Calleguas, the City's water supplier, has developed an Emergency Water Supply Plan that addresses availability of water supply during an outage of imported water. The plan may be found at: https://www.dropbox.com/s/f4qii3llzu4xnuh/Emerg%20Water%20Supply%20Plan%20Ju ne-2014.pdf?dl=0. The City of Port Hueneme participates with nine of the ten Ventura County cities, the County, and several water agencies (including Calleguas) every five years to develop a new Ventura County Multi-Hazard Mitigation Plan, most recently for a September 2015 update. This Plan assesses the risks posed by natural and human-caused hazards and establishes a mitigation strategy for reducing these risks. Hazards addressed include climate change, dam failure, drought, earthquake, flood, landslide, tsunami, and wildfire. The plan may be found at: http://www.vcfloodinfo.com/pdf/201five%20Ventura%20County%20Multi- Hazard%20Mitigation%20Plan%20and%20Appendices.pdf. Planning for management of groundwater water quality basin quality is primarily done by two agencies. The Los Angeles Regional Water Quality Control Board regulates groundwater quality through its Basin Plan. The plan may be found at: 250 North Ventura Road • Port Hueneme, CA 93041 • Phone (805) 986-6510 • Fax (805) 986-6581 www.cityofporthueneme.org

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http://www.waterboards.ca.gov/losangeles/water issues/programs/basin plan/basin pl an documentation.shtml. The Fox Canyon Groundwater Management Agency is currently preparing a Sustainable Groundwater Management Plan in accordance with the 2014 California Sustainable Groundwater Management Act. In any case, groundwater quality events such as seawater intrusion develop slowly and most water supplies in Ventura County are protected from contaminant spills because the aquifers are largely covered with an impermeable clay cap. UWCD Response to C-07 disagree. Plans to address water supply emergencies and groundwater quality exist, but are not prepared under the UWMP process. UWCD's critical facilities are the Santa Felicia Dam (SFD) which impounds Lake Piru and the El Rio Water Treatment Plant (WTP). Operation and maintenance of Santa Felicia Dam is regulated by two agencies; the Federal Regulatory Energy Commission (FERC) and California Department of Water Resources Division of Safety of Dams (DSOD). UWCD has implemented a dam safety program in which a Dam Safety Surveillance and Monitoring Report (DSSMR), Emergency Action Plan (EAP) and annual security letter are submitted and reviewed by FERC each year. The DSSMR provides a process for the real-time evaluation of the performance of the dam and appurtenant facilities. The EAP covers potential and imminent dam failure due to earthquakes and other events and describes in detail the response process and general responsibilities. These plans and oversight by state and federal agencies help to increase situational awareness as it relates to dam safety and also helps to identify potential projects to improve dam safety. UWCD currently has two projects underway to improve dam safety: outlet works rehabilitation and probable maximum flood containment. The El Rio WTP provides drinking water to the City of Oxnard, Port Hueneme Water Agency, Rio School District and several mutual water companies. The plant is regulated as a "Public Water System" by the State Water Resources Control Board Division of Drinking Water (DDW). UWCD has implemented a Water System Emergency Response Plan (ERP) which covers potential failures due to earthquakes and other events and describes in detail the response process and general responsibilities. This includes the Oxnard-Hueneme (O-H) Pipeline and potential pipeline leaks and breaks. For power failures, the El Rio WTP is equipped with a 750 kilowatt emergency back-up generator to run the groundwater well field, in addition to electric and natural-gas powered booster pumps to maintain pressure in the O-H Pipeline. El Rio currently has 16 million gallons of clear-well storage which stands at a higher elevation than the majority of O-H Pipeline customer turnouts and can provide water by lower-pressure gravity flow if necessary. Additionally, UWCD participates in the Ventura County Multi-Hazard Mitigation Plan which was last updated in September 2015. This plan assesses the risks posed by natural and human-caused hazards and establishes a mitigation strategy for reducing 250 North Ventura Road • Port Hueneme, CA 93041 • Phone (805) 986-6510 • Fax (805) 986-6581 www.cityofporthueneme.org

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these risks. Hazards addressed include climate change, dam failure, drought, earthquake, flood, landslide, tsunami, and wildfire. As mentioned previously under comment C-03, the GSP that is being prepared by and will be adopted by the FCGMA will address seawater intrusion. Future seawater intrusion abatement projects may be developed as a result of the GSP. The FCGMA and the Los Angeles Regional Water Quality Control Board are responsible for addressing issues related to groundwater contamination, which typically occurs slowly.

Water Considerations for Cities*

Conclusions 19

No Responses Found 1