Officers 

Harvey A. Bailey. President 

Joan Maher, /" Vice President 

Vacant, 2""' Vice President 

Sandy Willard Denn, J"'K/ce 

President 

Vacant, Treasurer 

Lawrence Bauman, Executive 

Director 

Board of Directors 

Northern Zone 

Mike Alves 

Kanawha & Glide Water District 

Lance Boyd 

Princeton-Codora-Glenn ID 

David Coxey 

Bella Vista Water District 

Sandy Denn 

Teltama-Colitsa Canal Authority 

Central Zone 

Alexander R. Coate 

East Bay Municipal Utility District 

Jerry Brown 

Contra Costa Water District 

Ted Costa 

San Juan Water District 

Joan Maher 

Santa Clara Valley Water District 

Western Zone 

Dennis Falasehi 

Panoclte Water District 

Anthea Hansen 

Del Puerto Water District 

Martin Mclntyre 

San Luis Water District 

Frances Mizuno 

San Luis <t Delta-Mendota WA 

Southern Zone 

Harvey A. Bailey 

Orange Cove Irrigation District 

David Nixon 

Arvin-Edison Water Storage District 

Ronald D. Jacobsma 

Friant Water Authority 

Eric Limas 

Lower Title River Irrigation District 

1521 "I " Street 

SacraiTiento, CA 95814 

Tele: 916-448-1638 

Fax: 916-446-1063 

Email: 

Larry: Ibaumantajcvpwaler.ort; 

July 25, 2014 

Ms. Brooke Miller-Levy, Project Manager 

Central Valley Project Cost Allocation Study 

Bureau of Reclamation, MP-730 

2800 Cottage Way 

Sacramento, CA 95825 

Subject: Central Valley Project (CVP) Water Association (CVPWA) Comments on 

Reclamation's CVP Cost Allocation Study (CAS) Wavier Regarding the Following: 

(1) Period of Analysis and (2) When to Apply New CAS Percentages to CVP 

Construction Costs 

Dear Ms. Miller-Levy: 

CVPWA offers the following comments regarding Reclamation's Mid-Pacific 

Region's (Region) proposed subject waiver as discussed at July 8, 2014 meeting: 

1. CVPWA concurs with the Region's decision to use 100 years beyond the 

completion of the final CVP cost allocation as the period of analysis for the 

current CVP CAS. 

2. CVPWA does not have enough information currently to make an accurate 

and informed comment on preference regarding the starting date for applying 

final CVP cost allocation factors for CVP repayment purposes. When that 

information becomes available, CVPWA would like to have the opportunity 

to comment again on this matter. 

However, if we had to make a decision, our preference would be 2017, even 

though I indicated at the meeting that 2017 could be taken off the table and 

not be a consideration. Our rationale for this decision is as follows: (a) it is 

consistent with past CVP cost allocation updates and applications to apply 

the new factors prospectively; and (b) it complies with Reclamation Manual 

Directives and Standards PEC 01-02 on Project Cost Allocations. 

CVPWA looks forward to its continued participating with Reclamation throughout 

this important process. If you have any questions regarding these comments, please 

contact me at 916-448-1638 or lbauman@cvpwater.org. 

Sincerely, 

d f3a. 

Lawrence J. Bauman, Executive Director 

Central Valley Project Water Association 
cc: via e-mail only 

Mr. Jason Phillips 

Deputy Regional Director 

Bureau of Reclamation, MP-115 

2800 Cottage Way 

Sacramento, CA 95825 

Ms. Brenda Bryant 

Assistant Regional Director for Business Services 

Bureau of Reclamation, MP-110 

2800 Cottage Way 

Sacramento, CA 95825 

Ms. Michelle Denning 

Regional Planning Officer 

Bureau of Reclamation, MP-700 

2800 Cottage Way 

Sacramento, CA 95825