By Nicola Ulibarri
California uses plans as a primary tool for managing water throughout the state. Regulations like the Urban Water Management Planning Act of 1983, Regional Water Management Planning Act of 2002, Water Conservation Act of 2009, and Sustainable Groundwater Management Act of 2014 require local water agencies to write plans documenting their available water supplies and develop approaches to use water more sustainably and/or ensure a secure supply. This blog probes the goals California has in requiring local and regional water plans, and asks whether the plans are a good tool for achieving more sustainable water use.
California loves water plans, but without much justification
Since the 1980s, plans have been a go-to tool for the California state legislature and the Department of Water Resources (DWR). Plans are just one of many different policy tools the state could use to shape how Californians use and manage water. For instance, they could directly regulate how much different industries can use, they could implement a new tax to encourage conservation, or they could require the use of specific water saving technologies; each of these tools are used by state agencies in other policy domains. However, the state has been reluctant to regulate water use directly, instead setting broad goals (like achieving sustainability) and getting local actors to decide how they want to achieve those goals (individually or within a region) and codify those strategies within a plan.
If we examine the legislation that authorizes DWR to require water management plans, we find relatively little justification for why they chose a plan as opposed to any other tool (Escobedo Garcia and Ulibarri 2022a). In each statute, the legislature lays out detailed and explicit goals for achieving water security, encouraging conservation or regional coordination, or enhancing long-term sustainability – but then legislates the use of plans without discussion of their strengths or weaknesses. As an extreme example, in SB X7-7 (which authorizes DWR to require Agricultural Water Management Plans), the rationale for requiring irrigation districts to write plans is simply because other water agencies have to: “Urban water districts are required to adopt water management plans… [and] Agricultural water suppliers that receive water from the federal Central Valley Project [CVP] are required by federal law to prepare and implement water conservation plans… [Therefore] Agricultural water suppliers [including those who do not receive CVP water] shall be required to prepare water management plans to achieve conservation of water” (CWC §10,801). They assume that planning is good, and therefore require plans.
California water plans are good at managing for water quantity, but overlook environmental and social impacts
To understand what objectives water management plans are achieving, we can assess the written content of a plan, to see what dimensions of water management they discuss. As an example, a plan that focuses entirely on human uses of water, without discussing any environmental consequences of where that water was obtained from, is unlikely to intentionally improve environmental quality if implemented. Likewise, a plan that has a detailed evaluation of how climate change is likely to affect future water availability is more likely to develop management approaches that take that variability into account.
In reviewing plans written by water agencies in the Kings, Cosumnes, and American watersheds (Escobedo Garcia and Ulibarri 2022b), we found that across all plan types, they had a thorough discussion of water supply available in their jurisdiction, including an analysis of current and future conditions (Figure 1). Almost all plans discussed water quality, but less than half incorporated more than a brief discussion, suggesting a lack of attention to potential contamination issues.
Relative to water supply, plans had far less attention to environmental dimensions of water management (e.g., species or ecosystem health), the impact of climate change on the water cycle, or even human-environment dimensions like water for agriculture. However, the category that was least likely to be discussed was the social impacts of water supply, either socioeconomic impacts (e.g., a lack of water for disadvantaged communities) or health-related impacts from contamination – almost no plans discussed either topic in detail.
Finally, all plans detailed a variety of management tools to improve the sustainability and security of water supplies in their jurisdictions. Coordination activities (e.g., plans to hold annual stakeholder meetings) were the most commonly proposed tools, followed by monitoring. Less common, but still present in about half of the plans, were conservation activities or strategies to build new infrastructure or update existing infrastructure.
Water agencies write plans because they have to, but don’t necessarily implement the plans
We can also look at the content of the plans to assess how useful that plan is as a tool to guide actual management of water. With the exception of quantifying their water supplies, most plans appeared to meet the minimum guidelines required by DWR, rather than adding detail that would render the information in the plan more useful. For instance, despite proposing a number of management tools, very few of the plans included details about how those tools would actually be implemented – who would implement them, on what timeline, or with what funding. Even the most thorough plans overall – Groundwater Sustainability Plans – suffered from this limitation, with most plans to implement managed aquifer recharge suffering from a lack of feasibility (Ulibarri et al. 2021). Other evidence that the plan contents weren’t implemented comes because updated versions of the plans (most of which are required on 5-year cycles) would explicitly say they hadn’t implemented prior proposed activities, often citing a lack of funding.
Interviews with the agencies that authored water management plans confirmed that the plans were written because they were legally required, but did not guide the agencies’ day to day actions. For instance, they told us, “We use the urban water management plans as a… planning tool just to comply with state law because we have to, but when a new development comes in, we’re not pulling that out and looking at okay, did we account for that?” and, “We do Urban Water Management Plans. Those are required every five years by law, so we have to do those.” The water agencies used other documents, such as Water Master Plans, for their day-to-day decisions, not those required by DWR.
California loves its resource management plans. And to comply with planning requirements, Californians spend large amounts of time and money: water utilities drafting or contracting out the plans, stakeholders crafting detailed comments on plan drafts, and state agencies writing guidance documents, conducting trainings, and reviewing submissions. However, in light of worsening droughts, ecological collapse, and unequal access to clean drinking water, it’s necessary to think critically about whether plans are the best tool, or are being best employed, to solve ongoing water challenges.
Nicola Ulibarri is an Associate Professor of Urban Planning and Public Policy at the University of California, Irvine.
Escobedo Garcia, N., & Ulibarri, N. (2022a). Plan writing as a policy tool: instrumental, conceptual, and tactical uses of water management plans in California. Journal of Environmental Studies and Sciences, 1-15. https://doi.org/10.1007/s13412-022-00754-0
Escobedo Garcia, N., & Ulibarri, N. (2022b). Planning for effective water management: an evaluation of water management plans in California. Journal of Environmental Planning and Management, 1-21. https://doi.org/10.1080/09640568.2022.2082930
Ulibarri, N., Escobedo Garcia, N., Nelson, R. L., Cravens, A. E., & McCarty, R. J. (2021). Assessing the feasibility of managed aquifer recharge in California. Water Resources Research, 57(3), e2020WR029292. https://doi.org/10.1029/2020WR029292