# Prescription method memo: basin three (the Indian Wells Valley Groundwater Basin, California) **Date:** 2026-07-29. **Seat:** Fable (wave builder seat). **Status: PROPOSED, NOT RATIFIED.** No value reaches the registry until the operator ratifies this memo (wave contract gate, unchanged). Method authority: the basin one memo's ratified parameterization (`PRESCRIPTION_METHOD_MEMO_2026-07-29.md`: X=12, K=5, N=3, cadence 8y, the waterless-exclusion rule, the S table), REUSED. Candidate confirmed by the operator 2026-07-29 (the re-sequencing instruction: the dry basin lands first); the instrument brief's remaining proposals (`docs/AQUADRIO_BASIN_THREE_INSTRUMENT_BRIEF_2026-07-29.md`) ride this memo's §8. Primary documents on disk at `~/aquadrio-data/iwv/`. **The one-sentence result.** California's regime ratifies, for the first time in this wave, a numeric basin-wide quantity ceiling (sustainable yield 7,650 AFY, state-approved) and a ratified water budget in deficit, which engages the ratified S table's budget row for the wave's first S below 1.00 and puts the dial at **0.083 L/kWh (strict-under)** [PROPOSED]; the per-facility TRANSLATED operand is nonetheless honestly absent, because the regime's own allocation machinery assigns compute no share of the yield and prices above-allocation pumping instead of capping it. **What this corrects in the brief.** The brief forecast the wave's first translated operand and first populated AllocationBasis. The primary text says otherwise: the ratified volume is basin-wide, the regime's allocation answer for a new industrial user is zero-at-a-price, and a zero share converts to no positive per-kWh ceiling (the registry schema refuses non-positive operands by design). What the basin actually delivers is the first real S engagement: the basin's own ratified budget enters the dial and cuts it to less than a third of the wet basins' 0.30. The locality the wave promised arrives through S. **Evidentiary posture, per leg.** Translated leg: absent; the instruments are documented in §3 from primary text on disk, so the absence is verifiable. Dial leg: stronger here than in basins one and two, because for the first time a basin's own ratified instrument (the DWR-approved budget) enters the number; the US frame from basin one (judicial notice for cited ratified instruments; the MACT parentage of the method) travels intact. --- ## 1. The map: the regime's own ratified boundary Water Code §10722, verbatim: "Unless other basin boundaries are established pursuant to this chapter, a basin's boundaries shall be as identified in Bulletin 118." The basin is **DWR Bulletin 118 basin 6-054, Indian Wells Valley** (the DWR determination names it "Basin No. 6-054"; the SGMA portal row reads "6-054 INDIAN WELLS VALLEY"). The boundary is the state's own ratified line; we translate it, never draw it. 597 square miles across Kern (~73%), Inyo, and San Bernardino counties (GSP ES 2.2, PDF p. 32). - **Identifier [PROPOSED]: `CA-IWV` at the ratified jurisdictional level "statute"**, reusing basin two's accommodation: the Bulletin 118 boundary is statutorily incorporated by §10722, so the level string remains honest. If the operator prefers a distinct level for regulatory-atlas boundaries, it is one ratified string (§8.1). ## 2. The descriptive layer: P holds at the national band, S carries the locality P = 0.30 L/kWh, unchanged: the top of the operator-reported band for the best demonstrated water-using configuration (airside economizer + adiabatic cooling, 0.1 to 0.3 L/kWh, LBNL 2024 p. 47), per the ratified anchor rule. Two honesty notes specific to this climate: - **The direction reverses from basin two.** The Mojave's heat raises adiabatic assist hours, so the band's top is the anchor here, not a cushion. The method's design already answers this: P is the national technology floor; the basin's condition enters through S, which is where this basin does its work (§4). - LBNL's 965-station TMY set includes Mojave desert stations, so no adjacent-band widening is needed (the small-N clause stays untriggered); the Ren dataset carries no IWV city and contributes nothing under the named-lineage rule. C(b) unchanged: 3 metered facilities in the band retire the model. ## 3. The normative layer, from primary text on disk ### 3.1 The SGMA frame and the critical-overdraft designation Water Code §10721(w), verbatim: sustainable yield is "the maximum quantity of water, calculated over a base period representative of long-term conditions in the basin and including any temporary surplus, that can be withdrawn annually from a groundwater supply without causing an undesirable result." §10721(y): a water budget is "an accounting of the total groundwater and surface water entering and leaving a basin including the changes in the amount of water stored." §10720.7(a)(1) put every critically overdrafted high- or medium-priority basin under a GSP by January 31, 2020. DWR's criterion: "A basin is subject to critical overdraft when continuation of present water management practices would probably result in significant adverse overdraft-related environmental, social, or economic impacts." The GSP's own statement (ES 1.2, PDF p. 29; body 1.4, PDF p. 66): "In its 2016 Bulletin 118 interim update, the California Department of Water Resources (DWR) identified the IWVGB as a critically overdrafted basin of medium priority," and "DWR Bulletin 118-16 (dated January 2016) indicates the IWVGB is subject to critical conditions of overdraft" (ES 2.1, PDF p. 32). ### 3.2 The ratified numbers: yield and the budget in deficit From the 2020 GSP (Final_GSP.pdf, on disk): - **Sustainable yield 7,650 AFY** (ES 3.1.5, PDF pp. 39-40): DRI's long-term average natural recharge estimate (McGraw et al 2016; Garner et al 2017; recharge area ~770 square miles), adopted as "the Current Sustainable Yield of the Basin." - **The ratified budget, Table ES-1 (2011-2015 average, PDF p. 39):** inflows 7,650 (mountain-front recharge, the only inflow line); outflows 32,640, of which **groundwater extractions 27,740**, ET 4,850, interbasin flow 50; **change in storage -24,990 AFY**. The plan's own words: "outflows are approximately four times the estimated inflows"; overdraft documented "since at least the 1960s" (Dutcher and Moyle, 1973). ### 3.3 The state ratification DWR, January 13, 2022 (dwr_doc_5246.pdf, on disk, 51 pages): "the Department ... has determined the GSP is approved"; the Statement of Findings records that the Plan "satisfies the objectives of the Sustainable Groundwater Management Act (SGMA) and substantially complies with the GSP Regulations," with recommended corrective actions for future updates; evaluation duty per Water Code §10733 and §10733.4; signed by the Deputy Director for Sustainable Groundwater Management. This is the instrument that makes §3.2's numbers state-ratified rather than merely local. ### 3.4 The allocation machinery, and the per-facility finding GSP ES 5.1 (PDF p. 52), verbatim where quoted: the primary management action is "the establishment of annual groundwater pumping allocations of the safe yield, which is currently estimated to be 7,650 AFY, for each IWVGB pumper after consideration of Federal Reserve Water Rights, California water rights, beneficial uses of groundwater, historical groundwater production (particularly during the Base Period between 2010-2014), and municipal requirements for health and safety." The allocations "will be used for the purpose of assigning pumping fees ('Augmentation Fees')," and, decisively: "these Annual Pumping Allocations are not a determination of water rights in that they do not prohibit the pumping of groundwater. Rather, all groundwater pumpers continue to possess the right to produce groundwater provided they pay the Augmentation Fee." Base-period pumpers outside the annual allocations receive a one-time, non-transferable Transient Pool Allocation with a fallowing buy-back; year-one production was expected near 12,000 AFY plus transient agricultural pumping; the plan tolerates "some reasonable overdraft" until imported supply arrives (ES 5.2: the imported-water keystone; "Should development of imported water become infeasible, pumping may need to be reduced to 7,650 AFY"). **The finding.** The regime ratifies the volume (7,650) and then answers the share question itself: allocations key to 2010-2014 production, federal reserved rights, and municipal health and safety. A new compute facility has none of these; its share under the regime's own machinery is ZERO, and its pumping is lawful anyway at the fee. A per-facility consumptive-use ceiling therefore does not exist in the instruments: what exists is a basin-wide yield plus a price schedule. Translating the zero share would produce no positive per-kWh operand (the schema refuses non-positive ceilings by design), and translating the fee would price, which the body never does. **Translated operand: ABSENT. AllocationBasis: EMPTY**, and for a sharper reason than in basins one and two: the allocation question was asked and answered by the regime, and the answer is zero-at-a-price. We document its answer; we do not replace it with a share of our own. ### 3.5 The price instruments, documented, never translated The Augmentation Fee mechanism is ratified in the GSP (§3.4). The implemented rate is the IWVGA Replenishment Fee, **$2,130 per acre-foot** on pumping above allocation [PRIMARY-CITE PENDING: the IWVGA fee ordinance/resolution and current schedule, at ratification; corroborated by SJV Water and KVPR coverage, 2026-05, "more than $2,000 per acre foot"]. Context prices from IWVGA's own FAQ (2025-01-24, on disk): imported water $2,880/AF; recycled water $4,000 to $6,000/AF. Same posture as Quebec's royalty: the fee is the regime's own statement of scarcity, in dollars. Aquadrio counts, never prices. ### 3.6 The superseding instrument in waiting: the adjudication A comprehensive groundwater adjudication is live; IWVGA's own FAQ names the Indian Wells Valley Water District's "legal action against the state-approved GSP and the U.S. Navy." DWR's April 21, 2026 letter (dwr_doc_11925.pdf, on disk) records: the safe-yield trial "presently set for June 1, 2026"; DWR will review the District's proposed safe-yield estimate as TECHNICAL ASSISTANCE under Water Code §10729(b) (declining §10737.4(b) Alternative review because the submission "does not constitute a complete stipulated judgement"); and a settlement would "support a physical solution to replace the current [GSP]." That last phrase is the state agency naming the instrument-migration path itself. **C(a) is ARMED three ways:** entry of judgment or approval of a physical solution (the yield re-derives and the instrument identity migrates); DWR's technical-assistance finding on the competing safe-yield estimate; and the 2025 periodic-evaluation outcome (DWR correspondence of 2025-02-12 and 2026-01-15, on disk, still open). Until any of those lands, the ratified instrument in force is the approved GSP, and this memo's numbers carry that vintage explicitly: **ratified AND contested is the honest label**, stated together wherever basin three is rendered. ### 3.7 Federal reserved rights, context only China Lake NAWS holds federal claims outside SGMA's reach; 472 of the basin's 597 square miles are Navy-held or BLM-managed (IWVGA FAQ p. 8). Like Hydro-Quebec's leases in basin two: it shapes who shares the yield, never whether a ceiling exists. The Navy's rights are among the allocation considerations in §3.4, which is one more reason the compute share is zero. ### 3.8 The live application, context only RB Inyokern (CEC Small Power Plant Exemption path, filed April 2026): approximately 50 AFY of proposed groundwater cooling draw (reported 40,430 GPD) inside this basin, with water the contested question in coverage [docket-cite at ratification]. An application, not an operating draw; it enters the record as the first candidate this prescription would grade, and nothing else. ## 4. The first derivation with a live S, worked > Aquadrio prescribes a direct water ceiling of **0.083 L/kWh (strict-under)** > [PROPOSED] for **the Indian Wells Valley Groundwater Basin (DWR Bulletin 118 > basin 6-054, boundary as statutorily incorporated by Water Code 10722)**, > effective **on ratification**, version **1**, because: (1) efficient > facilities demonstrably run **0.1 to 0.3 L/kWh** (LBNL 2024 p. 47, > operator-reported, best demonstrated water-using configuration; P = 0.30, > the band's top, per the ratified anchor rule); (2) the basin's governing > regime carries a **ratified budget in deficit** (GSP Table ES-1, > DWR-approved 2022-01-13: extractions 27,740 AFY against sustainable yield > 7,650 AFY), engaging the ratified S table's budget row, **S = 7,650/27,740 > = 0.276**, the budget itself the citation; (3) the derivation rule maps (1) > and (2) to 0.30 x 0.276 = 0.0827, published at two significant figures > rounded toward achievability: **0.083**. > > The regime ratifies a basin-wide sustainable yield and no per-facility > consumptive ceiling: its allocation machinery keys to base-period > production, federal reserved rights, and municipal health and safety, and > prices pumping above allocation (the Augmentation Fee) rather than > prohibiting it (GSP ES 5.1). The record states this in place of a > translated operand. The two-verdict rendering: > The basin's governing regime sets a basin-wide sustainable yield (7,650 > AFY, GSP, DWR-approved 2022) and allocates it by base-period production, > federal rights, and municipal need; it sets no per-facility consumptive > ceiling, and above-allocation pumping is lawful at the published fee. > Facility allocation standing: [reported per facility]. > Aquadrio certifies at 0.083 L/kWh (strict-under), per the basin three > prescription v1 [when ratified]. Facility meets this bar: [per record]. > The mark requires the facility's lawful standing AND Aquadrio's bar. Registry entry this ratifies into (shape only, values PROPOSED): `Prescription(basin=BasinId("CA-IWV", "statute"), boundary="strict_under", effective_date=, version="1", ratified_by="operator", derivation_ref="calibration/water/PRESCRIPTION_METHOD_MEMO_2026-07-29_BASIN3.md", translated_ceiling_l_per_kwh=None, dial_ceiling_l_per_kwh=0.083, allocation_basis_id=None, dial_ref="this memo sections 2 and 4")`. ## 5. The dial leg against the five factors 1. **Testability.** Every input is on disk or one URL away: the GSP PDF, the DWR determination PDF, two Water Code sections, one ratio, one multiplication. A challenger reruns all of it in minutes. 2. **Peer review and publication.** LBNL-2001637 is a reviewed federal lab report; the GSP is a public agency plan evaluated and approved by the state under Water Code 10733; the budget's recharge estimate carries its own published lineage (DRI, McGraw 2016). 3. **Known or potential error rate.** The honest weak factors, stated: the budget is a 2011-2015 model-vintage estimate, and the yield is under active adjudication challenge with DWR's technical review open. Both are C(a) triggers, not footnotes; the vintage travels on every rendering (ratified AND contested). C(b) unchanged: metering replaces modeling at N=3. 4. **Standards controlling the technique.** MACT parentage throughout, unchanged; the S row's input here is the strongest kind the table contemplates, a state-approved budget rather than a screen or a designation. 5. **General acceptance.** Sustainable-yield accounting is SGMA's own statutory frame (10721(w)); the state's approval of these specific numbers is on file. The dial's locality rests on the basin's own arithmetic, not ours. ## 6. The water-energy tradeoff, named Nowhere does it bite harder than a desert basin: dry cooling buys near-zero site water with more electricity, and the penalty lands where the carbon gate and the indirect-water record already look. The waterless-exclusion rule and the register's two-axis rendering carry it, unchanged (basin one memo §6). A facility beating 0.083 in the Mojave by burning kWh will show exactly that on its record. ## 7. Inputs (the C(a) watch list) | Input | Vintage | Supersession consequence | |---|---|---| | IWV GSP (Final_GSP.pdf, on disk) | Adopted January 2020 | Amendment or replacement re-derives sections 3 and 4 | | DWR "Approved" determination (on disk) | 2022-01-13 | Withdrawal or re-determination re-derives section 3.3 | | GSP Table ES-1 budget | 2011-2015 average | **A revised ratified budget re-derives S (armed: 2025 periodic evaluation open)** | | Adjudication (safe-yield trial) | Trial set 2026-06-01; judgment pending | **Judgment or physical solution re-derives the yield and migrates the instrument (armed)** | | DWR 10729(b) technical review | Open, 2026-04-21 letter | Finding re-derives section 3.6 posture | | IWVGA Replenishment Fee schedule | $2,130/AF [PRIMARY-CITE PENDING] | Rate change updates section 3.5 (documented only) | | Bulletin 118 COD designation | January 2016 interim update | De-designation re-derives S classification | | LBNL-2001637 | Dec 2024 | New water figures re-derive P (shared, all basins) | | RB Inyokern CEC docket | Filed April 2026 | Decision converts context to a gradable facility | | Water Code 10721/10722/10720.7 (fetched 2026-07-29) | Current | Amendment re-derives section 3.1 | ## 8. [OPEN], honestly listed 1. Ratify: `CA-IWV` at the existing level "statute" (or name a distinct level string for regulatory-atlas boundaries). 2. Ratify the S budget-row formula (S = ratified yield / ratified current extractions, both from the basin's own approved budget table) and the precision rule (dial published at two significant figures, rounded toward achievability; 0.0827 -> 0.083). 3. Ratify dial 0.083 L/kWh strict-under. 4. Ratify the zero-share finding standing in place of a translated operand (the brief's forecast corrected; AllocationBasis stays empty because the regime answered the share question itself). 5. Ratify the vintage label: basin three renders as ratified AND contested (approved GSP; adjudication and DWR review open) wherever it appears. 6. Fee primary-cite (the IWVGA ordinance/resolution) at ratification, per the Quebec Gazette precedent. 7. Whether the RB Inyokern application is named in the registry notes or stays memo-side. ## 9. Sources - IWV GSP: iwvga.org/wp-content/uploads/2026/06/Final_GSP.pdf (on disk; cited by PDF page with ES page labels). - DWR determination and Statement of Findings: SGMA portal document 5246 (sgma.water.ca.gov/portal/service/gspdocument/download/5246; on disk). - DWR letters: portal documents 10855 (2025-02-12), 11871 (2026-01-15), 11925 (2026-04-21); all on disk. Assessment record: sgma.water.ca.gov/portal/service/gsp/assessments/59 (JSON; "APPROVED" 2022-01-13, correspondence entries as listed). - Water Code 10721, 10722, 10720.7, 12924: leginfo.legislature.ca.gov (fetched 2026-07-29, quoted verbatim). - DWR critically overdrafted basins page (criterion verbatim) and Bulletin 118 interim update 2016 (designation; GSP self-statement page-cited). - IWVGA FAQ 2025-01-24 (on disk): federal land share, imported/recycled water prices, the District-litigation characterization. - LBNL-2001637 (shared anchor; basin one memo section 2.1). - Secondary, context only: SJV Water / KVPR (2026-05, RB Inyokern; fee magnitude), Maven's Notebook (2026-06-11, Phase 2), somachlaw policy alert (the SPPE path).