Back in 2013, NRDC partnered with the Pacific Institute to examine the first round of Agricultural Water Management Plans (AWMPs). These plans were supposed to include basic information, such as where water supplies come from, the type and acreage/area of crops grown, and whether districts had implemented certain efficiency practices (some which are mandatory, and some which are exemptible).
We were interested in what narratives the AWMP data would show. Would the data identify leaders in adoption of efficient water use practices? Would we be able to identify trends based on district size or geography? Would there be opportunities to share best practices among districts?
However, once we dug into the reports, we found that most districts did not even complete their required AWMPs. The lack of thorough, standardized data in the completed reports and the public availability of some of the reports, made it very difficult to gain any useful insights or identify trends in water use.
AWMPs aren’t the only agricultural water use reporting requirement fraught with compliance and data transparency issues. The same issues crop up with regard to “Farm Gate Delivery Reports,” (FGDRs) which should document total water deliveries for all districts who deliver water to 2,000 irrigated acres or more. Yet, a recent report shows that only 12 percent of the State’s largest irrigation districts turned in all their required FGDRs over the past 5 years.
NRDC has offered suggestions to improve both the AWMP and FGDR process. Five years after the last AWMP report, one additional round of AWMPs to analyze, and a massive drought later, are we any closer to a more useful planning process for California’s largest agricultural water users?
The Good News
- New legislation will require e-filing and standardized data reporting. Earlier this year, the California Legislature passed a pair of bills that seek to “Make Conservation a California Way of Life”: AB 1668 and SB 606. This new legislation requires districts to file their plans electronically, use a standard format so data can be better analyzed across plans, and requires the Department of Water Resources (DWR) to post the plans online. Read more about the legislation, which NRDC helped champion, from my colleague Tracy here.
- AB 1668 also gives DWR new enforcement tools to improve compliance rates. The new legislation allows DWR to contract with academics or engineering firms to complete a plan on behalf of a delinquent district—and to charge the cost to the district. If the delinquent district fails to provide data needed to complete a plan, DWR can issue fines of $1,000 per day, up to $25,000.
- DWR has created an online database of AWMPs and FGDRs.
The Bad News
- There is still no “master list” identifying which districts need to complete plans and reports. A basic first step toward getting complete compliance is identifying who is subject to the requirements. Yet DWR does not yet have such a list.
- DWR’s online clearinghouse needs work. Although creating a data portal for AWMPs and FGDRs is a great first step, DWR could make some improvements to make their site even more useful. For example, the AWMP database currently does not have the 2012 AWMPs loaded into it, nor does it contain information about the date AWMPs were due and the date they were received.
- Revisions to AWMPs that emphasize “Water Balances” and “Quantification of Efficiency” could lead to fuzzy math and no useful data. The new legislation includes a shift toward more quantitative planning, asking districts to calculate water balances based on all inflows and outflows, and to assess their water use efficiency. However, it is not immediately apparent that enough data exists to calculate an accurate water balance. Most agricultural water suppliers do not currently directly measure key components of a water balance. Instead, water suppliers will need to infer the values of some components (e.g., deep percolation) from the value of other components that have a high degree of variation (e.g., crop ET). These inaccuracies and inferences will compound one another, leading to “water balances” that are neither accurate nor useful. In fact, agricultural water suppliers have raised many of these same concerns in comments submitted to DWR. Furthermore, districts can choose one of four methods to calculate their water use efficiency, which will make it difficult to analyze efficiency data across different locations and time periods.
DWR is holding stakeholder engagement sessions and accepting comments on implementation of AB 1668 and SB 606. NRDC will participate in this process and encourage DWR to:
- Improve transparency, including creating a master list of districts required to submit Farmgate Delivery Reports and Agricultural Water Management Plans.
- Improve the online clearinghouse so that it includes relevant information, such as date of submission.
- Provide timely guidance to assist districts with new, standardized reports. Previous guidance has been released too close to reporting deadlines to be useful for districts. DWR could consider borrowing tables and formatting guidelines from the US Bureau of Reclamation (USBR). Since USBR’s water users are allowed to turn in their federal water conservation plans to satisfy state AWMP requirements, it would make sense to have consistent tables and formatting for both processes.
- Take a robust view of their compliance role. Historically, DWR has not had many tools at its disposal to ensure districts’ compliance with planning and reporting requirements. However, the new legislation allows DWR to ensure plans get completed, even if districts are unable or unwilling to complete the plans themselves. DWR should make the most of this opportunity to ensure that plans not only are complete, but are substantively useful, and are actually examining the potential for adoption of efficiency practices, drought resiliency improvements, and long-term sustainability.