We analyzed the Department of Public Utilities’ long range water supply plan draft. There are some problems with it. We wrote a letter to the Board of Public Utilities outlining our concerns. Here’s the text of our letter (PDF version also available):
Dear Mr. Johnson and BPU members:
I write on behalf of the Pajarito Conservation Alliance, a non-profit community organization that supports the ecosystems and outdoor experience of the Pajarito Plateau.
We have reviewed the Long Range Water Supply Plan draft dated November 2016 and have several concerns, which are summarized in this letter under three themes.
First, the draft does not sufficiently consider water conservation. That is, the draft says that conservation is good but does not incorporate it into any of the scenarios. We believe this is insufficient for the following reasons:
The impact of conservation on demand is not quantified. As the draft states, “further reductions in per capita demand are expected” (p. 68), but rather than attempting to quantify these reductions, the draft instead assumes that conservation demand reductions equal the high-side error in LANL estimates. These two things are not the same, and it is inappropriate to misuse conservation to offset deficiencies in LANL-provided documents. Reasonable estimates of high and low conservation effects are available and should be used.
The draft understates conservation opportunities. Specifically, the goal of 12% per capita reduction in demand by 2050 (p. 89) is unrealistically low. For example, Las Vegas, Nevada reduced its per-capita demand by 40% in 25 years , and the Los Angeles Metro’s water use was the same in 2014 as 1970 , despite growing from 10 to 18 million people.
The draft references legally required conservation planning on pp. 1–2 but does not address whether water supply plans must actually plan for conservation and what the relevant criteria are. These criteria along with a justification of how they are met should be included.
Second, we find the claim that San Juan-Chama water is a good hedge against supply/demand imbalance unconvincing:
Surface water such as SJC will be significantly less reliable than groundwater in a drier climate (p. 82). That is, the draft states that diversification of water sources is important (p. 42) but does not quantify the value of SJC water for this purpose. Quantifying the expected value of specific diversification scenarios will avoid false confidence. That is, simply having diverse water sources it not enough; the plan must convincingly justify each source in the proposed mix.
The alternative of drilling new groundwater wells upstream of potential contamination is not sufficiently analyzed. No financial analysis versus White Rock Canyon wells is presented. Several risks of new wells — that drilling permits might be unobtainable (p. 47), that “technical and legal fees” might be prohibitive (p. 43), that other municipalities “encountered difficulties” in trading or purchasing water rights (p. 46) — are advertised but not quantified. This produces an invalid cost/benefit analysis.
A scenario where LANL does not lease its water rights to the county but nevertheless forces the county to supply it with water (p. 74) seems far-fetched and should be either convincingly justified or removed.
The draft does not quantify the possible effects of return flow credits (p. 47, etc.), which again distorts the cost/benefit analysis.
Third, the draft does not consider the impacts of San Juan-Chama water development on White Rock Canyon:
The canyon contains numerous springs. “[G]roundwater that would have naturally discharged to the river” does so via springs. This is the very definition of a spring: a place where groundwater emerges to the surface. Thus, an approach that develops SJC water via wells in or near White Rock necessarily impacts springs; the only question is which ones and by how much.
These springs support state-listed sensitive species that would also be impacted.
Regardless of whether the approach involves groundwater interception, development of SJC surface water anywhere in White Rock Canyon is likely to impact the White Rock Canyon Archaeological District.
We realize that the draft is not an environmental or cultural assessment. However, such assessments are expensive, and Los Alamos rate-payers should not be expected to shoulder those costs without a reasonable likelihood of success. This includes both an acceptable outcome of the assessments and a proper cost/benefit analysis supporting the alternative that requires the assessments.
In short, while the draft spends a lot of words on conservation, its proposed actions largely ignore conservation opportunities, and its cost/benefit analyses are distorted in favor of expensive, environmentally damaging policies. This way of thinking will harm the future of our community.
We urge you to revise this plan as described above, in order to incorporate the quantitative, evidence-based reasoning and conservation values prized by the citizens of Los Alamos. We look forward to remaining engaged with this water planning process.
/s/ Reid Priedhorsky
Secretary, Pajarito Conservation Alliance
The board discussed the letter briefly during its December 22 meeting (video; discussion is 2:04:15–2:09:15). The chair, Jeff Johnson, wrote us back briefly the following day:
Thank you for taking the time to review the draft Long Range Water Plan and for providing input from the Pajarito Conservation Alliance. Public input is a vital and important part of our process. The BPU had it’s [sic] regular monthly meeting last night (12/22/16) and I discussed your letter with the Board.... Our consensus was that your comments have been received by the Department and they will be formally addressed during the development of the Final Draft.
When the BPU is presented with the final version of the plan, I (and other BPU members, I'm sure) will consider your comments in our review of the document.
It sounds like the board will revisit the issue in January or February. We will keep you updated. If you’re interested in helping out on this issue, please let us know.