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

15. Water Supply Management Practices
groundwater storage programs. Additionally, water banked by South Bay Aqueduct contractors
is modeled as one demand, but CALSIM II does not route the water to Kern County.
Response to Comment 30-128
The Settlement Agreement established an EIR Committee to provide advice and
recommendations to the Department in connection with the preparation of the draft and final
versions of the Monterey Plus EIR. The EIR committee included four SWP Contractor
Representatives and four Plaintiff representatives. A number of interim documents were
provided to the EIR Committee by the Department at intervals during the DEIR preparation
process to facilitate input by the EIR Committee. Comment 30-128 is a comment on an interim
document provided to the EIR Committee by Plaintiff representatives in July 2005 and was
considered in the course of the preparation of the DEIR. It was resubmitted in January 2008 as
an attachment to the Planning and Conservation League’s comment letter on the DEIR
(Comment Letter 30). Specifically, the interim document asks if the acquisition of non-Table A
(Turnback Pool, Article 21) water by SWP contractors has increased Delta exports.
As summarized in DEIR Chapter 6, Subsection 6.4.5, the water supply management practices
as a whole have increased Delta exports. The increase in Delta exports is also discussed in
FEIR Subsection 15.2.2. The combined results of the analyses in the DEIR portray the total
water supply impacts of the water supply management practices, including the Turnback Pool,
as described in DEIR Chapters 6 and 7 (Subsections 6.4.5 and 7.1.3). No separate estimates
of SWP supply changes attributable to the Turnback Pool alone are available, although its
influence on Delta exports is included in the analyses in DEIR Appendix K.
As stated on page 6-58 of the DEIR, if the Table A water offered through the Turnback Pool
from 1996 to 2004 (922,697 AF) had not been delivered to contractors via the Turnback Pool, it
might have been used by the original contractor, allocated to other contractors by the
Department, stored by the Department in Oroville or San Luis Reservoirs, or might have flowed
out the Delta. However, the amount of water being offered to the Turnback Pool each year
continues to decrease as demand within each contractor’s service area increases. See FEIR
Subsection 15.2.6.
The comment also mentions the price and volumes of water moved through the Turnback Pool.
The amount of money that contractors receive from selling their water through the pool does not
provide them with a profit, but merely offsets some of the costs they must pay regardless of
whether they take delivery of the water. Thus selling water through the Turnback Pool is not a
profitable venture and there is no economic incentive for use of the pool other than to gain some
revenue to offset part of the cost of water that would otherwise have been used as defined in
the preceding paragraph. Two pools offer selling contractors just one-half or one-quarter of the
full cost that they pay per AF of annual contractual Table A amounts for the development of
such supply. The money received covers just a portion of this cost, which they pay every year
regardless of whether or not they are allocated or receive such contractual Table A amount.
The comment notes a price for Article 21 water and infers that because it is cheaper than
Table A water that it has increased exports. The Department notes that pre- or post-Monterey,
there was and is no capital cost associated with Article 21 water in comparison with Table A
water. Additionally, the Monterey Amendment did not change the availability of Article 21 water,
just the priorities for receiving it and allocation of the available supply. See FEIR Subsection
14.2.4.
Final Environmental Impact Report February 2010
Monterey Plus 15-47