Final Environmental Impact Report (FEIR) - California Department of ...

9. Reliability of Water Supplies and Growth
Article 21(g)(1) were not eliminated. FEIR Subsection 9.2.5.3 also includes an analysis of the
effects of operating the SWP with Article 18(b) invoked and limited or no Article 21 water
delivered to SWP contractors. This analysis is not presented as an alternative or as a
modification of any alternatives discussed in the DEIR, but as clarification of why the
Department rejected the approach as an alternative.
Water reliability/ability to respond to shortages - As stated in the DEIR on page 9-11, the “paper
water” problem is really a question of whether local planners recognize the limitations on the
reliability of SWP supplies and more specifically whether the Monterey Amendment contributed
to misunderstandings of water reliability. Like most other surface water supplies, SWP water
supplies fluctuate, so in some years more water may be available and in other years less water
may be available. The Department has determined that invocation of Article 18(b) and returning
to the application of the concept of safe or firm yield in determining the amount of Table A that
can be reliably allocated each year, except in extreme droughts, is not a reasonable way to
protect the Delta or to make local government aware of the variability and limitations of SWP
water supply. Such an action would not alter Delta exports, would not alter water supply
reliability, nor would it alter the total amount of SWP water allocated to contractors. The action
would decrease Table A allocations and commensurately increase Article 21 allocations, both
as scheduled surplus and as unscheduled (interruptible) supplies. See FEIR Subsection 9.2.3
(same as 13.2.2.3).
As discussed in FEIR Chapter 7, Subsection 7.2.2.1.3, the Department considers current
regulatory processes and evolving Delta constraints to be the appropriate means of protecting
the Delta and other environmental resources. As discussed in FEIR Chapter 9, Subsections
9.2.4 and 9.2.6, the Department considers processes such as the Reliability Report (which
addresses the impact of climate change and Delta pumping restrictions) and other means of
urban water management planning to be a more effective means of making local government
aware of the variability and limitations of the SWP water supply. See FEIR Subsection 9.2.3
(same as 13.2.2.3).
FEIR Subsection 9.2.5.1 and 9.2.5.2 summarize and clarify the conclusions of the DEIR that
use of Article 21 water and elimination of Article 18(b) and Article 21(g)(1) do not contribute to a
“paper water” problem and explain why the Department has determined that invocation of
Article 18(b) and returning to the application of the concept of safe or firm yield in determining
the amount of Table A that can be reliably allocated each year, except in extreme droughts, is
not a reasonable way to protect the Delta or to make local government aware of the variability
and limitations of SWP water supply.
See also Response to Comment 17-1 in FEIR Chapter 13.
Response to Comment 17-2
The comment states concerns with the analysis of Article 21 if Article 18(b) were invoked. The
comment also claims that contractors have become dependent on surplus water supplies. See
FEIR Subsections 9.2.2 and 9.2.5. See also Response to Comment 17-1 and Response to
Comment 17-2 in FEIR Chapter 14.
Response to Comment 17-12
The comment raises questions about the analysis of the provisions of Articles 18 stating that the
analysis should include a discussion of reduction in supplies to the contractors. See FEIR
Final Environmental Impact Report February 2010
Monterey Plus 9-28