January 24,2014 

Harvey A. Bailey Michelle H. Denning 

Chairman o/the Board Regional Planning Officer 

NickCanata Bureau of Reclamation 

Vice Chairman 2800 Cottage Way, MP-700 

Tom Runyon Sacramento, CA 95825 

Secretaryflreasurer Via email: mdenning@usbr.gov 

Ronald D. Jacobsma 

General Manager 

Jennifer T. Buckman Subject: Comments on the Draft Delta-Mendota Canal/California Aqueduct Intertie 

General Counsel (Intertie) Cost Allocation Information Report - Central Valley Project 

Dear Ms. Denning: 

Member Agencies 

Arvin-Edison W.S.D. Thank you for the opportunity to comment on the Intertie Cost Allocation Delono-Earlimart I.D. 

Exeter I.D. Information Report (Report). On behalf of the Friant Water Authority's (FWA) 

Fresno I.D. twenty member districts, we concur with the general approach taken by Reclamation Ivanhoe I.D. 

Kaweah Delta W.C.D. in determining allocation of the Intertie, namely, to be based on expected benefits 

Kern-Tulare W.D. and beneficiaries. Lindmore I.D. 

Lindsay-Strathmore I.D. 

Lower Tule River I.D. We do, however, have the following comments relative to the cost allocation Maderal.D. 

Orange Cove I.D. analysis: 

Pixley I.D. 

Porterville I.D. 

Saucellto I.D. Allocation of Intertie as a separate facility: We support the view that the Intertie is a 

Shafter-Wasco I.D. facility distinct from the Jones Pumping Plant and the Delta-Mendota Canal and Stone Corral I.D. 

Tea Pot Dome W.D. provides benefits primarily to a distinct group of water contractors and thus a 

Terra Bella I.D. separate allocation of the facility to those primary beneficiaries is warranted. Tularel.D. 

Cross Valley Contractors: As you are aware, FWA represents the three largest 

Cross Valley Contractors. Those contractors have indicated that Cross Valley water 

supplies are transported from the Delta exclusively by the State Water Project 

facilities. If Intertie costs are to be allocated to Cross Valley Contractors, further 

explanation is needed as to the frequency and magnitude of the use of the Intertie to 

provide Cross Valley water supplies that would support the allocation derived in the 

Report. 

Main Office Sacramento Office 

854 N. Harvard Avenue 1107 9th Street, Suite 640 

Lindsay, CA 93247 Sacramento, CA 95814 

Phone: 559-562-6305 Phone: 916-346-4165 

Fax: 559-562-3496 Fax: 916-346-3429 

Website: www.frlantwater.org 
Michelle H. Denning 

January 24,2014 

Page 2 

North-of-Delta Agriculture: It is not clear how benefits are derived from the Intertie for Northof-Delta Agriculture. As the North-of-Delta contractors are not in the geographical area served 

by the DMC/San Luis facilities, an explanation of benefits to those contractors is needed. 

South of Delta Agriculture Allocation: Given current operations and priority of water service, it 

is fairly clear that the vast majority of the benefits are for CVP South of Delta (San Luis Unit) 

Contractors. It is less clear if the Intertie would be used exclusively for agricultural water 

deliveries as there is no allocation of Intertie costs to South of Delta M&I contractors. An 

explanation may be in order demonstrating the basis for the allocation solely to agricultural 

purposes. 

Assessment of costs to other water contractors: As we have expressed previously, in the event 

the Intertie is used intennittently by parties other than those allocated capital costs under 

Reclamation's ratesetting and cost allocation policies, such parties should have the appropriate 

capital rate component assessed and applied against the Intertie costs, comparable to the way 

incremental costs are assessed for transferred water when additional facilities are used beyond 

facilities allocated to the party benefiting from the transfer. For example, should it be 

determined that absent the Intertie, Exchange Contractor deliveries would not have been 

satisfied, the Exchange Contractor water would be assessed the Capital Rate on the volume of 

water deemed satisfied because of the ability to utilize the Intertie. The same would hold true for 

Cross Valley water or recirculation water under the San Joaquin River Settlement. 

Nexus to Intertie O&M cost allocation: Finally, while this analysis is focused on allocation of 

the capital costs of the Intertie, as you are aware, the San Luis and Delta-Mendota Water 

Authority (SLDMW A) and the FW A have a dispute with respect to allocation of O&M costs of 

the Intertie under the SLDMW A "Transfer Agreement". SLDMWA and FW A have requested 

Reclamation to provide its opinion on the appropriate O&M allocation of Intertie costs. FW A 

requests that Reclamation consider the Intertie capital cost allocation as it evaluates the O&M 

cost allocation for the Intertie as consistency would seem to be in order. 

Please feel free to contact me should you desire to discuss this further or if you would like to 

receive the information we have previously provided to Reclamation. 

Ronald D acobsma 

General Manager 

RDJ: tm 

cc: FW A Member Districts