Interim Management Policy
- Interim Management Policy Document – The text of the document signed by Inyo and LADWP; in effect 2007-2010.
**Text below summarizes the IMP; extracted from the Agenda Request Form for the 13 Mar 2007 Inyo Board of Supervisor’s Meeting**
At the Standing Committee meeting on 12 February 2007, the Inyo County/Los Angeles Standing Committee directed staffs to meet and negotiate an Interim Management Plan. They also directed that this item be brought to a Special Meeting of the Standing Committee scheduled for 19 March 2007 in Los Angeles. Your Board specified the Countys negotiating team include the Water Director, County Counsel, and CAO. Your negotiating team reached a tentative agreement with LADWP staff, and both parties agreed to present this plan to their respective decision-making Boards. A copy of the Interim Management Plan is attached. If approved by the Standing Committee, then this interim agreement must also be considered and approved by the LA Board of Water & Power Commissioners and your Board. The purpose of this agenda item is to allow your Board to consider and, if desired by your Board, approve this Interim Management Plan.
The Interim Management Plan was considered and reviewed by the Water Commission at their March 5, 2007 meeting. Following a presentation by the Water Director, the Commission recommended that your Board adopt the Interim Management Plan, as presented. A copy of the Water Commissions motion is attached.
The Interim Management Plan is a multi-year agreement that describes the groundwater management of LADWPs operations. The intent of the Interim Management Plan is to reduce the staff time requirement for both agencies, and redirect that staff time and effort to revisions of the groundwater management techniques. Existing groundwater management techniques are specified in the technical appendix to the Long Term Water Agreement (the Green Book). If implemented, the Interim Management Plan will supercede the Drought Recovery Policy for the term of the Interim Management Plan. The Interim Management Plan will not supercede the Long Term Water Agreement (Water Agreement) or the Green Book; rather, the Interim Management Plan functions as an overlay to those documents, preserving the existing components of the Green Book. For example,
- Wells that are in Off status under the Green Book will be in Off status under the interim agreement,
- Annual Operation Plans will be provided in accordance with the Water Agreement, and
- The Annual Operation Plans will abide by the groundwater mining provisions.
If, at the termination of this agreement, the County and LADWP have agreed to implement methodologies that replace or improve the tools and techniques for achieving the goals of the Water Agreement, management of the water resources of the Owens Valley will be in accordance with those modifications. To the extent that modifications have not been agreed to, management of the water resources of the Owens Valley will revert to the existing provisions of the Water Agreement and the Green Book upon termination of this agreement.
Concerning water management, the key points to the Interim Management Plan include:
- Pumping for the 2006-07 Runoff Year will remain under the existing Operations Plan, with pumping limited to 57,412 acre-feet per year (afy).
- Pumping will be planned to maintain the April 1, 2007 water levels for each successive April 1st during the term of the Interim Management Plan. Each Annual Operation Plan will be based on the regression equations agreed to by the staffs of both agencies. The wellfield pumping outlined in the Annual Operation plan will be reasonable, feasible, and result in the same average depth-to-water (DTW) in the wellfield for the following April 1st.
- The Bishop Cone will not be managed under this plan; rather, the Bishop Cone will continue to be managed under the Hillside Decree and other applicable rulings.
- Pumping in the Lone Pine Wellfield will be limited to providing the towns water supply and irrigation for the E/M projects.
- Exempt wells identified in the Interim Management Plan (Exhibit B) may be operated, as necessary, to supply the designated use, and pumping from the well for the designated purpose will not be limited, even if this operation of the well will prevent attainment of the applicable wellfield target level for the following April 1st. The exempt pumped water will count towards the wellfield total during a runoff year. If the operation of a well or wells identified in Exhibit B prevent the attainment of the applicable wellfield target level for the following April 1st, no well in the wellfield, other than those identified in Exhibit B, will be operated.
- If the April 1st predicted runoff exceeds 130% of normal precipitation, then LADWP will operate the McNally Canals and spread/irrigate a minimum of 10,000 acre-feet.
- Wells may be exempted from the provisions of this agreement for the purpose of testing, if test criteria are agreed to by both Inyo County and LADWP at a Technical Group meeting.
- LADWP uses groundwater pumping to provide freeze protection for the Los Angeles Aqueduct based on the ambient water and air temperatures. If necessary, wells may be operated for the purpose of freeze protection for the Aqueduct even if the operation of the well will prevent attainment of the applicable wellfield target level for the following April 1st.
- Total Owens Valley pumping by LADWP in any runoff year must be maintained within the historical range of pumping since the 2000-01 runoff year. During that time period, the minimum pumping was in the 2005-2006 runoff year (56,776 acre-feet). Maximum pumping was in the 2003-04 runoff year (87,726 acre-feet).
The benefit of this approach is that the management of groundwater pumping is based on direct management of the DTW. Each Annual Operations Plan will be an action plan that actively manages the groundwater level for the successive year. Therefore, if the pumping does not hit the DTW target precisely, then the subsequent years pumping plan will adjust to achieve the April 1st target.
The purpose of the historical pumping limits is to prevent pumping plans that had unworkable low or high pumping. Groundwater levels will likely rise in high runoff years, and in-valley uses will be maintained in low runoff years. However, there are two limitations to this approach. First, very low runoff may not provide sufficient water to recover the water tables to the April 2007 level, even at minimum pumping. Second, increases in the groundwater caused by high runoff could be reduced in subsequent years as the water levels are lowered to the April 2007 target.
The Interim Management Plan is structured so that each agency provides staff for the effort. In addition, LADWP and the County will share out-of-pocket expenses. For the Countys share, LADWP will provide $100,000 that goes to a trust fund administered by the County. If the initial amount is not adequate for the Green Book revision process, then additional funds will be deposited upon agreement of the LADWP General Manager and the Inyo County CAO. Expenses will be shared on an equal basis, unless otherwise agreed to by the LADWP General Manager and the Inyo County CAO. The funding terms of the agreement also allows for LADWP to audit the Countys expenses for up to three years following the termination of a contract for the Green Book revision effort.
Inyo County will work with LADWP to develop and conduct a joint study to explore the feasibility of utilizing groundwater beneath Owens Lake to assist in the dust mitigation measures. Details of this study will be worked out in a separate agreement.
The term of the Interim Management Plan is three years, terminating on March 31, 2010. Either party can terminate the Interim Management Plan by providing written notice by March 1st of each year of the agreement. Notice signifies that the party is withdrawing from the Plan for the following runoff year. Once the March 1st date has passed, both parties are obligated to remain in the agreement until the following March 31st. The term can be increased by the mutual agreement of both parties.
It is recommended that your Board consider and adopt the Interim Management Plan provided by staff. The Plan cannot be implemented until the Standing Committee has approved it.