Strategic Environmental Assessment: Integrated Regional Water Management in Los Angeles

To meet the demand for water in the Greater Los Angeles Area, the federal, state, and local government agencies have worked to develop a large system of infrastructure that brings water from all across the western part of the US to Southern California.

In the early 1900s, when the population of Los Angeles began to outgrow the water provided by the Los Angeles River, William Mulholland, Supervisor of the Los Angeles Department of Water and Power at the time, was commissioned to find a new source of water in order to supply the growing community. Between 1908 and 1913, the Los Angeles Aqueduct was constructed to bring water from Owens Valley to Los Angeles – a distance of 233 miles. Later projects commissioned by Mulholland would bring water form Mono Basin (338 miles away) and the Colorado River. These sources are all still currently supplying the majority of the water demanded within the Los Angeles area today.

With these projects, the Greater Los Angeles Area has been reliant for a majority of its water supply on far away water sources for nearly a century. This system poses huge risks on the city for the future; the population in the area is continuing to grow while these water sources will become continually less reliable due to issues like climate variation, water scarcity and even drought across the Western portion of the US. In addition, the local sources of water in Southern California are also threatened by environmental degradation, causing the quantity and quality of the water to be at risk.

To combat these issues, the State of California has created a state-wide water plan, which sets some major strategic goals for the State in terms of water management. Since the 2005 California Water Plan, the State has emphasized the importance of regional collaboration on the issue of water management. It has stressed the importance of hydro geological areas working in collaboration in order to create Integrated Regional Water Management (IRWM) Plans that provide a unified strategy for water management within the region. The IRWM region is meant to create a set of strategic goals that they will then use as a guide when approving water management projects and infrastructure. The State of California believes that the IRWM program “incorporates the physical, environmental, societal, economic, legal, and jurisdictional aspects of water management into regional solutions through open and collaborative stakeholder processes to promote sustainable water use.”

Since the passing of the IRWM Planning Act in 2002, the State of California has approved 48 IRWM Regions covering 87% of the state’s geographic area and 99% of the state’s population. The State of California is currently working on creating a state-wide strategy for all of the IRWM regions in order to build on the current and past successes of IRWM; further enable, empower, and support regional water management groups; better align state and federal programs to support IRWM; develop a shared vision for funding priorities and financing mechanisms; and inform and influence future water management policies and investments for California.

As mentioned in a previous post, the Greater Los Angeles Area has created an IRWM Region that covers roughly 10.2 million people, portions of 4 counties, and 92 cities. The region accounts for 28% of the population of California. Within the Los Angeles IRWM region, the area is divided into 5 sub-regions (as illustrated in the image below). The Los Angeles IRWM approved their first Integrated Regional Water Management Plan (IRWMP) in 2006 “following a multi-year effort among water retailers, wastewater agencies, stormwater and flood managers, watershed groups, the business community, tribes, agriculture, and non-profit stakeholders to improve water resources planning in the Los Angeles Basin.” Currently, the Los Angeles IRWM region is going through a process of stakeholder engagement and consultation in order to evaluate and revise this strategy by the end of the year.

According to the Greater Los Angeles IRWMP:

The purpose of this Integrated Regional Water Management Plan (IRWMP or Plan) is to define a clear vision and direction for the sustainable management of water resources in the Greater Los Angeles County Region (Region) for the next 20 years, present the basic information regarding possible solutions and the costs and benefits of those solutions, and to inspire the Region and potential funding partners outside this Region. Moreover, it is to adopt solutions that make sense, are good for the community, and are economically feasible.

Within the IRWMP, the plan provides information regarding the governance process of the association; the stakeholders involved and the types of engagement used; and data about the physical characteristics of the region including the geographical characteristics, population and governance information, water supply, demand, and quality characteristics, and social trends and concerns for the region. The plan also includes a description of the objectives and their related targets that form the Greater Los Angeles’ IRWM strategy. These objectives and targets are listed under 5 main categories:

Strategic Assessment?

Although the Greater Los Angeles IRWM has created a plan that explains in detail the needs and opportunities for water management in the region, it is not evident that a strategic environmental assessment was implemented during the strategic planning of the objectives and targets, nor were used to determine the criteria for the selection of projects that will be implemented in order to reach these objectives.

Strategic Planning of Objectives and Targets:

According the IRWMP, in order to decide on the Plan’s objectives and targets, “An initial list of objectives was revised by a subcommittee of the Leadership Committee and then circulated for comment to the five Steering Committees, five Subregional stakeholder workshops, and one Regional stakeholder workshop. Stakeholder comments were reviewed and incorporated as appropriate into the objectives, which were then finalized by the Leadership Committee.” There is no mention of a strategic environmental assessment made in order to assess the impacts that may come from the different objective options. These goals were decided by stakeholder engagement and committee meetings, yet did not involve an assessment of the impacts associated with the possible objectives available.

Assessment of Potential Projects?:

The Plan discusses the process undertaken for a “call for proposals” in which the region requested that all stakeholders submit their proposals for projects and project concepts for consideration by the region in order to reach the Plan’s objectives. According to the IRWMP, stakeholders had identified 1,500 projects during this process. The report explains the efforts and analysis undertaken by the organization in order to find ways to integrate these projects, either geographically or strategically, and also discussed how these projects helped to develop the “vision for each subregion”. Additionally, the report identified new regional projects that could help “bridge the gap” between the proposed projects and the targets set within the IRWMP.

However, in terms of impact assessment of these proposed projects, the report states:

Although some conclusions may be possible from an analysis of the stated benefits provided for the projects and project concepts in the database, given the uncertain accuracy of the benefit information provided, an assessment of cumulative benefits of the stakeholder-identified projects and a comparison of the cumulative benefits to the planning targets was ultimately not included in this Plan.

In other words, given that the proposals lacked information regarding benefits and impacts of their projects, the IRWMP did not include this assessment within their plan.

What about an Impact Assessment of the IRWM Plan?

One of the chapters within the report does discuss the benefits and impacts involved in the implementation of the finished IRWM Strategy. While this chapter offers a rather in depth description of the benefits of implementing the plan, it does not provide significant information as to what the potential environmental impacts of implementing this strategy may entail. The report states:

Consistent with Section 15262 of the CEQA Guidelines, a project involving only feasibility or planning studies does not require the preparation of an Environmental Impact Report or Negative Declaration but does require consideration of environmental factors.

Therefore, given the fact that it is a strategy, and not a project, a full environmental impact assessment (in California, this assessment is called the California Environmental Quality Act (CEQA) Guidelines) was not done.

The report goes on to say that:

To consider potential environmental effects that could result from IRWMP implementation, the CEQA Initial Study Checklist contained in Appendix G of the CEQA Guidelines (OPR, 2003) was reviewed to identify whether the implementation of the Plan, which might include those project concepts identified in the Regional Planning Tools, could result in adverse affects.

The report states a “summary of potentially adverse project-specific and/or cumulative affects that could result” from the implementation of the plan. The list includes impacts such as visual impacts from the new installations, air and noise pollution during construction, soil erosion, and land change issues.  As a disclaimer to their analysis, the report states that “this review is not intended to replace or supplant detailed review of potential environmental impacts (at such time as specific projects are proposed)”.

The impact analysis of the IRWM Plan concludes by stating:

Any decision to implement any individual project or program identified in this plan would be subject to CEQA compliance at such time as any agency commits to fund or implement the project. It is assumed that the approving entity would comply with CEQA and identify appropriate mitigation measures to the extent that any significant impacts would result.

In other words, the plan was not given a full environmental impact assessment; however, if any portion of the plan were to be implemented through a specific project, that project would need to go through a proper environmental impact assessment.

Conclusion:

While the Integrated Regional Water Management Plan for the Greater Los Angeles Area does consider the needs, opportunities, and potential benefits of the strategy within their report, there is little evidence that the potential environmental impacts were considered during the planning of the strategy. The brief impact assessment that was performed was done once the strategy had already been created.

Additionally, the IRWMP did not attempt to assess the cumulative impacts of the proposed projects that were submitted during the “call for proposals”, nor did they do a strategic environmental assessment based on the possible project opportunities.  The report simply states that once a given project has been chosen for implementation, the project will go through the standard Environmental Impact Assessment process required by the State of California in order to assess the impacts of the individual project.

Although the Los Angeles IRWM has examined the needs and opportunities of the region in detail and has succeeded in including their stakeholders within the creation of the plan, the process lacks the use of a strategic environmental assessment (SEA) as part of the strategic planning process. If the Los Angeles IRWM would have incorporated a SEA within their strategic planning, they would have had a better understand the impacts associated with the possible opportunities and solutions that they were considering for the final strategy.

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