Los Angeles Department of Water and Power chided for missing minimum stream flow targets and gaps in Mono Lake monitoring
By Bob Berwyn
FRISCO — Conservation advocates in California say recent failures by the Los Angeles Department of Water and Power to live up to the terms of a restoration agreement for Mono Lake show a lack of attentiveness to the crucial unfinished work of healing an ecosystem that was nearly destroyed by decades of water diversions.
The Mono Lake Committee, which advocates for the saline eastern California lake, detailed some of the violations in a letter to the California State Water Resources Control Board. The committee also outlined some of the issues in a recent update of its online newsletter.
LADWP started diverting the freshwater tributaries of the ancient saline lake in 1941. By 1982, the lake had dropped 45 feet, lost half its volume – and the salinity of the water doubled, resulting in all sorts of negative impacts to the unique desert-lake ecosystem and the riparian corridors along its tributaries. More details about the impacts of the diversions are online at this Mono Lake Committee web page.
One of the biggest concerns is the recent lack of monitoring in Mono Lake. Without that data, it’s impossible to know whether the state-ordered restoration goals are being met, said Mono Lake Committee director Geoff McQuilkin.
The committee wants the monitoring to be done by independent expert scientists with an understanding of saline lake ecology. Since DWP unilaterally took over the monitoring program last year, there have been gaps in critical data — in violation of State Water Board rules, according to McQuilkin.
“We’ve been back and forth with them about lake monitoring since 2008, when they (LADWP) sought to discontinue the entire program. They say the lake is fine; we say, no, it’s restoration in mid-progress,” McQuilkin said. You could have a lake level stay the same for a few years, and still have differences in lake ecology … we’re speculating that there’s an internal desire in DWP to get rid of lake health monitoring program,” he said.
Part of it may be based purely on the cost of the ongoing monitoring, but McQuilkin said it’s important to remember that LA diverts water worth about $12 million from the Mono Basin each year, and once the restoration goals are met, that amount could increase substantially, at least in some years.
In that context, the cost of monitoring is a small price to pay, McQuilkin said.
“These are very reasonable costs. It’s part of the modern way you manage a water system … And we’re getting up into lake levels that have never been scientifically studied,” he said. “We’re also expecting to see changes that won’t be DWP’s fault. Brine shrimp population dynamics are changing and that’s going to have some biological impacts.
“In a way, it’s an assurance program for DWP,” he said, adding that the water board wants monitoring to be able to distinguish impacts caused by restoration activities from naturally occurring changes.
“Without monitoring, we wouldn’t know salinity or brine shrimp populations … The bottom line for us, DWP needs to keep the promises made, and follow the rules the water board made,” he said.
The Mono Lake Committee also addressed a series of minimum stream flow violations in a separate June 19 letter to the State Water Board. The letter details a pattern of instream flow violations and reporting failures by LADWP during 2012.
The systematic failure to report the violations and the long duration of some of the incidents show that LADWP needs to step up its own procedures to ensure compliance with the restoration order, said Mono Lake Committee restoration specialist Greg Reis.
A Bishop-based LADWP spokesperson said the utility makes every effort to meet the overall stream restoration goals and to remediate errors as soon as possible.
“Many flow deviations … occur because the watershed hydrology is constantly changing day and night in response to temperature, weather, soil moisture, vegetation, and other factors. Changes are obscured by the time it takes for the natural stream systems to react and adjust, and the net effects are not known until the creeks stabilize,” spokesman Chris Plakos said via email.
“However, the unpredictable hydrology, delays in observing the effects of operational changes, and inherent margins of error in measuring natural stream systems underscore the difficulty and practical limitations of meeting exactly prescribed flows in a real-world application,” Plakos continued.
Reis agreed with parts of the DWP statement, but said the violations remain a concern for the committee and the still-recovering Mono Basin.
“A significant proportion will be minor, the problem is the ones that aren’t,” he said, adding that the minimum streamflow violations in Lee Vining Creek were especially surprising because the LADWP has updated its diversion mechanisms in that drainage.
The other big concern is the lack of reporting, which may by symptomatic of a lack of adequate staff or resources to properly manage diversions in the Mono Basin according to state requirements. Reis said his best assessment is that antiquated diversion facilities, not paying attention, and maybe not caring a little bit, as well as a lack of leadership, all played a role.
Two dry years in a row may have also been a factor, as LADWP started diverting water from two smaller tributaries it had left whole for the previous decade, including Walker Creek. The decision by DWP to divert from Walker Creek was puzzling, Reis said, because it doesn’t add to the total amount that LA is able to export from the Mono Basin.
But in 2012, LADWP’s operations on Walker Creek caused flows to fall up to 35 percent below the ordered instream minimum for a month. In total, 43 days were in violation, a full 58 percent of the days on which LADWP conducted diversions, according to the committee’s letter to the water board.
“In dry years, every drop matters. There’s not much growth … the dry years are hard enough already,” Reis said, explaining the restoration challenges in those small tributary streams.
“The impacts of these flow deviations on the still-recovering fisheries and stream habitats are unknown. Due to LADWP’s failure to report them, the State Water Board stream experts, California Department of Fish and Wildlife, and interested public were unaware of the problems and unable to consider steps to evaluate possible impacts,” the committee wrote in its letter to the state water board.
In another case, LADWP missed the seasonal changeover to a different flow level by about 10 days, “part of a pattern of not paying attention,” according to Reis.
The giant municipal water agency is getting ready to respond to the criticism, defending itself by saying that rigid streamflow regimes are unrealistic in a real world environment.
“LADWP is preparing a letter to the State Water Resources Control Board (SWRCB) in response to Mono Lake Committee’s allegations concerning stream flow requirements on the four creeks it manages in the Mono Basin (Rush, Lee Vining, Walker, and Parker),” Plakos wrote.
“Current Mono Basin stream operations are made in accordance with the Grant Lake Operation Management Plan as approved by the SWRCB when adopting its Order 98-05, which is still the controlling document at this time. That plan recognized that rigid flow schedules were unrealistic, and there must be flexibility in meeting the flow requirements due to changes in meteorological conditions, operational and physical constraints, errors in forecasting, and emergency situations.”
LADWP said it’s not required to notify the state water board of minor deviations from the required minimum flows, but follows the reporting rules when it comes to significant violations, including failure to meet an annual peak flow, or when there’s a potential adverse impact to a fishery.