Comments on the Colorado River Basin Study prepared by the the Western Water Policy Review Advisory Commission

Hess, Gordon A.

Water Authority, San Diego County

English

University of New Mexico

River Basin Studies Western Water Policy Review Advisory Commission (1997) 
4-8-1997 
Colorado River Basin Study Comments--San Diego County Water 
Authority 
Gordon A. Hess 
San Diego County Water Authority 
Follow this and additional works at: https://digitalrepository.unm.edu/law_service_westernwater_rbs 
University of New Mexico 
UNM Digital Repository 
Recommended Citation 
Hess, Gordon A. and San Diego County Water Authority. "Colorado River Basin Study Comments--San 
Diego County Water Authority." (1997). https://digitalrepository.unm.edu/law_service_westernwater_rbs/2 
This Technical Report is brought to you for free and open 
access by the Western Water Policy Review Advisory 
Commission (1997) at UNM Digital Repository. It has 
been accepted for inclusion in River Basin Studies by an 
authorized administrator of UNM Digital Repository. For 
more information, please contact amywinter@unm.edu, 
lsloane@salud.unm.edu, sarahrk@unm.edu. 
Mr. Dale Pontius 
Western Water Policy Review 
Advisory Commission 
PO Box 25007, D-5001 
Denver, CO 80225-0007 
Dear Mr. Pontius: 
The Authority appreciates the opportunity to review the Western Water Policy 
Review Advisory Commission's draft Colorado River Basin Study. We found the study 
to be a very good overview of events occurring on the river and believe this will be a 
valuable publication. Our comments include updates to subjects where events are 
occurring rapidly, corrections, and suggested editorial revisions. General comments 
are provided below, listed by subject, and proposed revisions are given on an 
attachment in strikeout/underline fonnat. 
Yuma Desalter (Pages 4, 103. 111) 
The first Salinity Control recommendation (page 111) states that the Yuma 
Desalter should be decommissioned. (This recommendation also appears in the 
Executive Summary on page 4.) However, this conflicts with the recommendation given 
on page 103, that states that a process should be developed that, among other 
decisions, "should decide the future of the Yuma desalter." Meeting salinity standards 
is a federal obligation, and operation of the desalter should be considered as one 
alternative in the future process. The recommendation to decommission the desalter is 
premature, coming before this process is developed. 
The discussion of desalter costs on page 111 should be compared to costs of 
other alternatives that are recommended in the draft, such as water reclamation. Also, 
replacement of desalter membranes is a normal practice, and is included within 
operation and maintenance unit cost estimates. 
Upper Basin Water Use (Page 17) 
The column labeled "Entitlement" of Table 4, Annual Water Use m the Upper 
Basin, should be explained. Why is the total Upper Basin entitlement 6 mat, and not 
7.5 maf? 
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Draft Colorado River Basin Study 
Page2 
Secretary Babbitt (Page 27) . . . 
At his speech to the Colorado River Water Users Assoc1at1on in December 1996,
Secretary Babbitt indicated that action on surplus criteria regulations would be
temporarily deferred until California was able to demonstrate a strateg� that would
assure the state's ability to reduce its use (to the state's 4.4 mat apportionment), when
necessary. The remarks on page 27 should be revised to reflect that there are 
conditions which must be met before surplus criteria will be formalized. See Proposed 
Revisions attachment. 
Supply augmentation (Page 29) 
What is the basis for the declaration that augmentation is "not a realistic option?" 
Unless support can be provided for this conclusion, the statement should be amended 
to read that an evaluation should be conducted to determine whether augmentation is a 
realistic option. 
Callfornla priority rights to water (Page 36) 
The text is incorrect in stating San Diego's priority rights to Colorado River 
water. See Proposed Revisions attachment. 
CW A/MWD negotiations (Pages 37, 105, 106) 
The Authority has not reached an accord with MWD for wheeling water in the 
Colorado River Aqueduct. See Proposed Revisions attachment. 
All-American Canal lining (Page 38) 
11D has declined to sign an agreement with MWD for the canal lining. See 
Proposed Revisions attachment. 
Flood releases on river (Page 38) 
It is not true that the 50 mat could have been diverted if reservoirs were 
operated differently. When MWD is operating its aqueduct at capacity and the 
reservoirs are full, there is no additional opportunity to divert water. It must by 
necessity flow to Mexico. The sentence beginning "California points out that in the 
1980s ... " should be deleted in its entirety. 
Sallnlty (Pages 67, 69, 71) 
The discussion of salinity control program goals on page 67 should include an
assessment of whether these goals are likely to be attained, given current conditions.
P�ge 69 �hould �e revised to reflect the fact that increased salinity levels in the San
Diego region during the 1980s were a result of the return to historic flows and TDS 
levels on the Colorado �iver (aft�r the 1983 flood flows and record-setting low TDS level_s) and M�� blending practices. On page 71, in light of the listed decreases in
!und1ng for salinity control, a recommendation should be considered that wouldincrease such funding. 
oraft Colorado River Basin Study 
page3 
Federal water subsidies (Pages 104, 105) 
The last paragraph on page 104, which is continued on page 105, should be 
rewritten to restrict comments about federal water project costs to the Colorado River 
system of dams and reservoirs, and not other federal water projects. For example, 
does the "ability to pay" policy exist for the Colorado River system, or is this true only 
for other federal projects, such as the Central Valley Project? Also, more detail should 
be provided on the M&I costs listed. Is the conclusion of the CBO report cited (that 
users pay only 20 percent of the cost of federal water) specific to the Colorado River 
Basin, or does it include all federal projects in the country? 
Water Reuse (Page 106) 
The last paragraph on this page does not reflect work being done on water 
reuse by the Authority and other agencies. The Authority does have an "integrated 
water resources plan" that fully considers water reclamation and reuse as potential 
resources. The Authority's Water Resources Plan was first written in 1993 and has 
been updated for 1997. Water reclamation is considered on an equal basis with 
imported water, local groundwater, seawater desalination, and conservation ( demand 
management), as potential resources. The International Wastewater Treatment Plant 
will dispose of 36,000 af/yr, and not 373,000 af/yr as shown in the draft study. 
Ecosystem Sustainability (Page 59) 
The statement that "a reasonable and prudent alternative will be developed ... if 
the BO results is (sic) a jeopardy opinion" is incorrect; RPAs are developed by the FWS 
to avoid the likelihood of jeopardy - not as a result of jeopardy. 
Again, thank you for the opportunity to provide these comments. Should you 
have any questions, please feel free to call me at 619-682-4155. 
Attachment 
Sincerely, 
Q 
Gordon A. Hess 
Imported Water Manager 
Attachment 
PROPOSED REVISIONS BY THE 
SAN DIEGO COUNTY WATER AUTHORITY TO THE 
WESTERN STATES WATER POLICY REVIEW ADVISORY COMMISSION'S 
DRAFT COLORADO RIVER BASIN STUDY 
Page 111: 
U-H ltis the obligation of the federal government to meet the salinity standards ... " 
Page 27: 
He promised action on the development of surplus oritoria and regulations necessary to 
implement the interstate component of the Arizona Water Bank.!, iss1:1es of oritioal 
importanoe to all three Lower Basin states- He also stated the need for formulating 
criteria that will govern the declaration of surplus conditions. but deferred making any 
surplus guidelines final until California puts into place a strategy to reduce demand to 
its 4.4 maf apportionment, when necessary. Both interstate banking and surplus 
criteria are of critical importance to all three Lower Basin states. 
Page 36: 
Under the Seven Party Agreement, San Diego has an equal fifth priority right to MWD 
for 112,000 af, although the San Diego allocation was consolidated with the MWD 
allocation under agreements made in 1946 and 1947, when San Diego became a 
member of MWD. and a seventh priority right up to 250,000 af, which is the-lowest 
priority among Claifomia 1:1sers. 
Page 37: 
San Diego decided it needed to find its own additional water supplies, gi11on its lowest 
priority in tho Seven Party Agreement diversity its sources of supply to improve 
reliability. and had negotiated directly with 110. Although it appears that M'A'D and 
SDC\AlA have roaohed an aooord on wheeling this water in tho M)A'D aquoduot (thus 
preoluding for now the need for San Diego to build a $1 billion plus pipeline) ... 
Page 37: 
Unfortunately, with heavy winter precipitation this year, some if not all of this water ·1.1ill 
be spilled, all of this water was spilled, underlining the difficulties with top water 
reservoir storage. 
Page 38: 
For example, MWD is also interested in pursuing a project, authorized by Congress, to
line the All-American Canal under which MWD could receive or bank over 67,000 af a
year for 55 years for its share of this investment. However, IID recently declined to
complete an agreement with MWD for this project, and whether MWD will ever be able
to participate in the project is uncertain.
1 
Page 69: 
Nelth San Diego region 
wastewater salinity has inc
reased over the past de
cade due,
· · · · · · · 
· to the r eturn of
historic TDS levels in the 
Colorado River and MWD 
ractices related to blendi
n 
Colorado River water with 
less-saline State Water Pr
o· eel su lies. Salini le
vels on
the river had reached his
toric low levels after the 198
3 flood flows and rose tow
ard 
historic average levels du
ring the remainder of the deca
d&. During this time MWD 
ch n e i s blendin racti
ces to rovide San Die o w
�h a su I that was hi he
r in
Colorado River water. and t
hus higher in TDS. 
The salinity of the Colorado R
iver has increased from a dry s
eason average of 485
ppm in 1986 (the lowest recor
ded levelUo over 700 ppm In 1
994. One of San Diego's
solution§ is to demineralize rec
laimed water. The initial 2J.-mgd
 facility will deliver 
3,600 1,200 ac-ft per year of RO
 product (to produce 4,000 af/yr blended 
supplyl_and is
expected to have a capital cost of
 approximately $+ 3.5 million and annual o
perating 
costs of $-h3 0.3 million .
Page 59: 
In anticipation of this possibility, in -1--994
 1993 the Lower Basin states and water u
sers
created a Steering Committee to explore 
options under the ESA to create a proactiv
e 
program that oould offset any Soetion 7 det
er-mlna-tlons that might impaot •Nater and 
power uses in tho Lo'l.'OF Basin and still moot r
ooo1.«ery plan objeotii.«es as well as 
proolude the need for now listings. accommodat
es current water diversions and powe r
production and optim�zes futur� water and power d
evelopment opportunities, works 
toward the co�s�rvat1on of habitat and toward reco
very of species, and precludes the
need for new listings. 
Page 105: 
For example, SD�WA plans to pursue additional agreements with 11
0 to free up,
throu_gh conservation and fallowing agreements, as much as 500 ooo af of water f ·t 
growing needs. 
• or I s 
f
Pa
1
ge _106: The last paragraph on this page should be deleted and replaced with the
o owing paragraph: 
As part of a move toward water use efficien 
. 
pursuing reuse of wastewater Th S . 
cy, many water agencies are 
a 1997 Water Resources Pia� sho:i�
n
t����
o
�
�un
� 
Water Aut�ority has developed 
region will increase fivefold between 1996 
ec a1me wa�er use in the San Diego 
current use up to a projected 60,000 af/ 
a
;� 
2?15• moving fr�m 11 ,400 af/yr of
of water. This innovative project would 
Y
�
:
r 
,s inclu�es a pro1ect for the potable reuse 
wastewater, including reverse osmosi 
u 11z� e�ens1ve trea�ment processes on 
water to a surface reservoir for future ��t
���h
nat,on, b�fore introducing the treated
SDCWA evaluated reclaimed sup lies on 
e use. In it� Water Resources Plan, the 
resources, including imported suiPr I 
the same basis as all other potential water 
conservation {demand managemen��
s, ocal groundwater, seawater desalination, and 
2 


Colorado River Basin Study Comments--San Diego County Water Authority

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Colorado River Basin Study Comments--San Diego County Water Authority

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