FINAL

- U.S. Bureau of Reclamation, Mid-Pacific Region

Criteria for Evaluating Water Management Plans

September 1996

These “Criteria for Evaluating Water Management Plans” (Criteria) were developed by the US Bureau of

Reclamation (Reclamation) in response to the Central Valley Improvement Act of 1992 (CVPIA) and in

accordance with the Reclamation Reform Act of 1982 (RRA).

All agencies (Districts) that contract with Reclamation for Municipal & Industrial (M&I) water in excess of

2,000 acre feet and/or for Agricultural (irrigation) water to serve over 2,000 irrigable acres will be evaluated

based on the required information detailed in the steps listed below. The steps are:

1. Describe the District

2. Inventory Water Resources Available to the District

3. Best Management Practices (BMPs) for Agricultural Contractors

a. Non-exemptible BMPs

b. Exemptible BMPs

4. Best Management Practices for Urban Contractors

a. Non-exemptible BMPs

b. Exemptible BMPs

5. Exemption Process

.~e data called for in the Criteria are not available, the District shall include in its plan how the District will

the data and have it available for the next plan update.

BACKGROUND AND GENERAL INFORMATION

Section 210 ofthe RRA requires districts with certain types ofBureau ofReclamation contracts to prepare and

submit Water Management Plans (Plans) with definite goals, appropriate water conservation measures, and

timetables. “Guidelines” for preparing these Plans were prepared and are updated by Reclamation., Mid-Pacific

Region every 5 years. Districts were asked to submit updated Plans every 5 years to reflect the specifics in the

revised Guidelines.

Section 3405 (e) ofthe CVPIA requires that the Secretary ofthe Interior establish criteria to evaluate Plans by

April 30, 1993, and that these Criteria be reviewed and revised, if necessary, at least every 3 years.

This law specifies that the Criteria identify best management practices (BMPs) including, but not limited to,

efficient water management practices being developed according to California State law or reasonable

alternatives. In addition, the Criteria are to grant substantial deference to the recommendations included in A

Management Planfoi Agricultural Subsurface Drainage and Related Problems on the Westside San Joaquin

Valley (September 1990).
Reclamation has been unable to wait for a conclusion to the California Agricultural/Public Interest Group Task

Force consensus discussions (instituted by Assembly Bill 3616) before issuing and revising these Criteria but

has incorporated the majority ofthe current AB 3616 language. Consensus BMPs for urban water districts

(resulting from an Urban/Public Interest Group Task Force) were incorporated into these Criteria in 1993.

When the Criteria are updated, Reclamation will consider modifications to reflect future consensus reached

between agricultural, urban and environmental and public interest groups.

PROCESS TO DEVELOP THE CRITERIA

The purpose ofthese Criteria is to promote the highest level ofwater use efficiency reasonable achievable by

project contractors using best available cost-effective technology and best management practices.

The revision ofthe 1993 Criteria began on September 12, 1995, when Reclamation sent the Criteria to the

interested public for review and comment. On the basis of oral and written comments; Reclamation’s experience

with administering the Criteria, and comments from the CVPIA -Public Forum Water Conservation Workteam,

Reclamation proposed changes to the April 1993 Criteria.

Draft Revised Criteria were distributed In mnre than one thous~nd interested parties in March 1996.

Reclamation received written corn .~

Reclamation received oral comments at three public workshops, with forty-one participants. Reclamation met

with members ofthe Central Valley Project Public Forum Conservation Workteam (Workteam) to discuss the

draft revised Criteria.

Major concerns expressed in written and oral comments, and by the Workteam included: consistency with the

AB 3616 draft MOU, the degree of measurement required by the Criteria, the nature ofpricing required by the

Criteria, and the possibility ofregional Criteria. Other significant concerns included: conditioning discretionary

benefits on Plan development and implementation, accommodation ofthe Management Planfor Agricultural

Subsurface Drainage and Related Problems on the Wesrside San Joaquin Valley (September 1990,), and the

inclusion of groundwater management plans. The current resolution ofthese concerns is reflected in this second

draft revised Criteria. Ifyou would like a complete copy ofthe comments and Reclamation responses, please

contact the Water Conservation Program Manager at (916) 979 -2388 (TDD (916) 979-2310).

Reclamation is releasing these revised Criteria while it works to develop a proposal for regional.Criteria, first

for the Sacramento Valley region and later for other regions ifit appears warranted. Reclamation will work

with concerned districts, public interest groups, stakeholders and the public to determine what regional Criteria

might be appropriate.

Annual Updates for districts that developed Plans under the 1993 Criteria will conform to the revised Criteria.

Implementation ofBMPs that were eliminated or moved to Attachment A in the revised Criteria will no longer

be formally reviewed by Reclamation.

As used in these Criteria, “water conservation” means:

Improved water management through the implementation of best management practices.

Although the term “Best Management Practice” has been used in various statutes and regulati6ns, the
definitions and interpretations ofthat term in those statutes and regulations do not apply to these Criteria. For

the purposes ofthese Criteria; “Best N4anagement Practice” means:

~olicy, program, practice, rule, regulation and/or ordinance, orthe use ofdevices, equipment or facilities

ich meets either ofthe following items:

1. An established and generally accepted practice among water districts that results in more efficient

use, conservation or management of water;

2. A practice for which sufficient data are available from existing water management projects to

indicate that significant efficiency improvements or management related benefits can be achieved; that the

practice is technically and economically reasonable and not socially or environmentally unacceptable; and that

the practice iS not otherwise unreasonable for most water districts to carry out.

Reclamation recognizes that these Criteria call for plans that are more detailed than those required before

passage ofthe CVPIA. To assist districts in developing adequate water conservation plans, Reclamation’s MidPacific Region area offices have Water Conservation teelmical staff that are aware ofand familiar with local and

area specific issues. Water Conservation staff are current with technical advancements and ~familiarwith

programs implemented within all regions ofthe State. Since the Criteria were developed in 1993, over halfof

CVP contractors above the threshold of 2,000 acre feet for N4 & I contractors or 2,000 irrigable acres for

agricultural contractors have developed and implemented plans that meet this Criteria.

Reclamation developed and distributed a Guidebook for Developing Water Management Plans detailing the -

type ofinformation required by the 1993 Criteria. This Guidebook will be updated to conform to the revised

Criteria.

BENEFITS OF WATER MANAGEMENT PLANNING

Planning for water management programs offers the opportunity for districts to coordinate efforts and think

about the best ways to implement programs before making any capital expenditures. Comprehensive planning

allows all affected parties - end users, District Board members and sta’ff- to be on the same path to accomplish

the same goals. Some districts have chosen to use these plans as a business plan, as a way to identify long range

activities and develop a stable program base.

Water Transfers

Water transfers may have, in some instances, a substantial part to play in good water management. Some

Districts have found that they can market water as a way to provide funding for water management programs.

Water transfers are legally recognized as a beneficial use ofwater. The CVPIA authorizes the transfer ofwater

outside ofthe CVP service area, subject to certain conditions, creating opportunities not previously available to

CVP contractors. In February 1993 Reclamation issued “Guidelines for Implementation ofWater Transfers,”

available upon request, that outline the procedures for water transfers within and outside ofthe CVP service

area.

3
Flexibility

These Criteria recognize the differences betxVeen districts and have been written to be flexible enough to allow

each district to develop and implement the types ofprograms that will best accomplish improved water

management within their boundaries. In some cases, districts may choose to pool resources and implementjoi

programs. These Criteria not only allow, but encourage.joint efforts toward program implementation.

Plan Implementation

Water management in general, and water management planning in particular, is an on-going process that does

not stop with the preparation of a comprehensive Plan. The purpose of preparing a Plan is for Districts to

implement the programs developed during the planning process. Implementation ofprograms identified in the

Plan is critical to the success of water management within a District. These Critefia focus not only on what

constitutes an adequate Plan, but also on the implementation ofthe programs described in that Plan. Districts

shall report on Plan implementation annually.

Consequences of Non-Compliance

Reclamation policy is to condition the granting ofcontract renewals on ~hedevelopment and good-faith

implementation of an adequate Water Management Plan. Because development and implementation ofa Water

Management Plan is an important tool for the evaluation ofproposals for water transfers, Reclamation

encourages that Plans be in place for Districts ~vishingto transfer water to other entities. -

Review Process

Districts that submit three copies ofa complete plan or complete revisions will receive, within 90 days,

notification ofReclamation acceptance or request for modification.

4
PLAN CONTENTS

‘p 1. Describe the District

Intent:

To describe general physical information about the District in order to form a basis for evaluating improvements

by, and within, the District, as well as provide the reader with information about physical aspects ofthe District

that may effect the potential for improved water management.

Evaluation:

Reclamation recognizes that in certain circumstances, specific information may not be available. In these

circumstances, the step will be considered “adequately addressed” ifthe plan describes how the information will

be obtained forthe next plan update.

Detail Expected in an Adequate Plan:

Water Management Plans shall describe the District history, location and facilities, size, terr-ain and soils,

environment, climate, operating rules and regulations, customer water delivery measurements, water rate

schedules and billing, and water shortage allocation policies. For data not available during the preparation of

this plan, the District shall describe how the information will be obtained for the next Plan update.

A. History: Give an historical overview ofthe District. Provide a timeline which includes the formation of

the District, original size, water supplies, contract information with Reclamation and others, and changes in land

use. For agricultural contractors, describe changes in irrigated acreages, cropping patterns, and evolving

~ation methods.

L Location and Facilities: Describe the water conveyance and delivery system within the District service

area (e.g., unlined canals, lined canals, pipelines, etc.), storage facilities (e.g., reservoirs, regulating reservoirs,

etc.). Agricultural Districts should describe spill recovery systems, and whether the delivery system is ondemand (no lead time or scheduling necessary), scheduled (i.e., order water 24 hours in advance), rotation

(farmer receives water every 10 days), or other. Describe any restric4ons on the District’s water source(s) and

proposed changesthat will be implemented in the next five years.

C. Topography and Soils: Describe the topography ofthe District (e.g., hilly, flat, sloping to a water

course, etc.). Indicate the impact oftopography on water operations and management within the District.

Districts with agricultural contracts over 2,000 irrigable acres, describe major soil classifications and

corresponding acreages within the District’s boundaries. Describe any soil limitations that affect the use of

water (e.g., salinity or high water table, extremely sandy soils, low infiltration rates, etc.).

D. Climate: Describe the general climate ofthe District. Include average precipitation, maximum and

minimum temperatures, average wind velocity and direction and frost free days. If, within the District, there are

known areas with significantly different microclimates, describe how these affect water management decisions

and operations.

E. Natural and Cultural Resources: Describe any known natural resources (e.g., wetlands, rivers,

streams, lakes, fisheries, threatened plant and animal communities, spawning grounds, flyways, etc.) within the

J ~t boundaries. Indicate any management ofthese resources in the past or present by the District. Describe

a. nown recreational and/or cultural resources within the District.

5
F. Opcrating Rules and Regulations: Describe or attach a copy ofthe District’s operating rules and

regulatibns. Agricultural contractors should include information on water allocation policies, lead time

necessary for water orders and water shut-off, any policies regarding return flows and drainage leaving the

District, and policies related to water transfers into or out ofthe District (farmer and District).

G. Water Measurement, Pricing and Billing: List the total number ofconnections! turn-outs, the number

currently measured and the percentage of customer water deliveries measured. List the types and numbers of

measurement devices (e.g., meters, calibrated gates, weirs, etc.), level of accuracy, frequency of calibration, and

maintenance and reading schedule.

Describe the basis for water charges for agricultural, municipal and industrial uses. A copy ofthe District’s

written operating rules and regulations will suffice ifthey include: basis for water charges for agriculture (e.g.,

by quantity, by acre, by crop, by land assessment, by other charges, etc.) and/or for municipal and industrial

(e.g., by customer class, by quantity, flat rate, etc.).

If water use is billed by quantity describe the rate structure (e:g., declining, uniform or increasing block rate,

etc.). Include the billing frequency (e.g., monthly. bimonthly, annually, etc.), bill format and a description of

the record management system.

H. ‘Water Shortage Allocation !)e!iciec: .Att2ch :~ce~~’ ofthe District’s agricultural and/or urban \vatcv

shortage policies.

Agricultural Districts shall describe how reduced water supplies, including hardship water, are allocated.

Describe District policies that address wasteful use ofagricultural water and describe enforcement methods.

Step 2. Inyentory Water Resources

Intent:

To describe the quantity and quality ofwater resources (sources, uses, and discharges) available to the District

in order to form a basis for evaluating improvements by and within the District, and to provide the reader with

an understanding ofwater available to the District, water used within the District, and water discharged from the

District.

Evaluation:

Reclamation recognizes that in certain circumstances, specific information may not be available. For these

circumstances, the step will be considered “adequately addressed” ifthe plan describes how the information will

be obtained for the next plan update.

Detail Expected in an Adequate Plan:

This step shall include a description ofthe District’s surface water supply, ground water supply, other water

supplies, source water quality monitoring programs, water uses within the District, agricultural drainage from

theDistrict, urban waste water disposal, and a water inventory. Provide this information for 1996. For data not

available during the preparation ofthis plan, the District shall describe how the information will be obtained for

the next plan update.

6
A. Surface Water Supply: Describe the acre-foot amounts delivered to the District by each ofthe

District’s surface sources for the specified x’ears. Describe any water quality limitations or management

concerns associated with the identified water sources. Provide the amount ofwater received under each right

.dlor contract for the last 10 years.

B. Ground Water Supply: Describe the general characteristics ofthe ground water basin(s) that underlie

the District. Provide a map locating District operated water ~vells,and managed ground water recharge areas. If

there is conjunctive use ofsurface and ground water, describe it. For managed ground water basins, attach a

copy ofthe management plan.

C. Other Water Supplies: Identify any long-term water supplies not described above (e.g., drainagefi-om

upstream Districts, reclaimed urban waste water, transfer agreements with adjacent or other Districts, etc.).

D. Source Water Quality Monitoring Practices: Describe any surface water or ground water quality

problems, and how the quality problems limit the use ofthe water or affect customer use decisions. If water

quality problems exist, describe the water quality testing program..(frequency ofmeasuring and analyses

performed) and which agencies conduct the water testing. Also describe the District’s role in the program.

E. Water Uses within the District

1. Agricultural: Describe the type and acreage of crops grown in the District; include evapotranspiration

rates, cultural practices and the leaching requirement for each crop. List the types ofirrigation systems used for

each crop.

2. Municipal and hidustrial: Describe the municipal and industrial water use, by customer type, within the

rict. Describe, where applicable, the waste water collection and treatment systems, recycled water uses and

~~odsofdisposal.

3. Ground Water Recharge: List the quantity ofwater used for planned and incidental ground water

recharge, including method ofrecharge.

-/. Transfers and Exchanges: Describe the source and quantity of water that was transferred and/or

exchanged into or out ofor within the District, and for what uses. Describe any other water transactions, such

as trades, wheeling, etc.

5. Other: Describe any other uses of water.

F. Agricultural Drainage from the District: Identify where surface and subsurface agricultural drainage

goes (e.g., to beneficial reuse within the service area, discharged to a river or other water course, another

District, saline sink, evaporation ponds, wildlife refuge, etc.). Ifdrainage leaves the District’s service area and is

reused, identify the location and type ofthat reuse, if known. Describe any water quality monitoring programs

for surface or subsurface drainage water (frequency ofmeasuring and analyses performed). Identify any

constituents (e.g., selenium, pesticides, etc.) that limit reuse ofthe drainage water. Describe any usage

limitation resulting from the drainage water quality.

Section 3405 (c) states that “the contracting district or agency shall be responsible for compliance with all

applicable State and Federal water quality standards applicable to surface and subsurface agricultural drainage

discharges generated within its boundaries.” Districtsincluded in the drainage problem area, as identified in A

Management Planfor Agricultural Subsurface Drainage and RelatedProblems on i’he Westside San Joaquin

V “oy ~“September1990,,), should also complete Attachment A.

7
C. Water Accounting: Develop a water inventory for the District based on 1996.

1. Quantifr District Water Supplies

a. Surface water supplies, imported and originating within District, by month.

b. Ground water extracted by the District, by month.

c. Effective precipitation by month.

d. Estimated ground water extracted by non-District parties(if records are not available, provide an

estimate and basis for estimation).

e. Recycled water by month (water originating from a municipal waste water treatment plant).

f. Other supplies by month.

2. Quantify Water Used

a. Conveyance losses, including seepage, evaporation, and operational spills.

b. Consumptive use by riparian vegetation.

c. Applied agricultural water, crop evapotranspiration, water used for leaching and cultural practices

(e.g., frost protection, soil reclamation, etc.)

d. Municipal and industrial water use.

e. Ground water recharge.

f. Water exchanges and transfers.

g. Estimated deep percolation within the District.

h. Flows to perched water table or saline sink.

i. Total M&I waste water treated and discharged.

j. Agricultural spill or drain water leaving the District.

k. Other.

3. Overall Water Inventory: Compare total water supplies entering the District with total water leaving th

District.

Step 3. Best Management PracticesforAgricultural Gontractors

Intent:

To develop an implementation plan for agricultural Best Management Practices (BMPs) that have been proven

to accomplish improved (more efficient) water management.

Evaluation:

Some BMPs are considered “universally applicable” and others are considered “generally applicable.”

Reclamation recognizes that, under certain circumstances, the generally applicable practices may not make

sense for District implementation. Districts will implement each generally applicable BMP unless the District

provides adequate documentation for an exemption.

Detail Expected in an Adequate Plan:

For the purposes ofthese Criteria, the plan needs to describe the program that the District determines will best

accomplish eachBMP. The success ofsome ofthe practices will depend on cooperative work with other

entities. There may be constraints to successful implementation ofplanned programs. Monitoring and updating

will allow the District to modify planned programs that do not accomplish the practice as designed.

8
A. Critical Best Management Practices for Agricultural Contractors

s section lists the BMPs that all Districts will implement or are already implementing. Provide a description

~ie implementation plan and include time schedules, budgets and monitoring plans. Districts may spend time

.dying the most effective way to implement a BMP. If a BMP is to be studied, please provide details and

schedules ofthe study.

1. Measurement devices - measure, with a device that is rated to have a maximum error of+ six percent.

the volume of water delivered by the District to each customer (within five years ofcontract renewal or

if no contract renewal date, by January 1, 1999);

2. Pricing structure - adopt a water pricing structure for District water users based at least in part on

quantity delivered;

3. Demand managementstaff - designate staff responsible for development and implementation ofthe

water management plan;

4. Water management services for water users - Provide or support the availability ofthe following

water management services for water users:

a. On-farm irrigation and drainage system evaluations (i.e., mobile labs)

b. Normal year and real-time irrigation scheduling and crop ET information (i.e., CIMIS)

c. Surface, ground and drainage water quantity and quality data;

d. Educational programs and materials for farmers, staff, and public.

B. Exemptible Best Management Practices for Agricultural Contractors

Each District shall develop a program to implement the following BMPs unless the District demonstrates that

practice does not make sense for the District to implement. Districts may spend time studying the most

Aive way to implement a BMP or whether a BMP is appropriate for a District, For appropriate BMPs,

ide a description ofthe implementation plan and include time schedules, budgets and monitoring plans. Ifa

BMP is to be studied, provide details and schedules ofthe study. These studies must be completed

expeditiously and before the next Plan update. Districtsshould follow the exemption criteria (see Step 5) to

justify exemptions and provide the exemption in this Step. See Attachment B for examples ofcircumstances

under which BMPs are not applicable.

I. Distribution system lining/piping - line or pipe distributions systems to increase distribution

system flexibility and capacity, decrease maintenance and reduce seepage;

21. Regulatory reservoirs - constructregulatory reservoirs to improve distribution system deliver)’

flexibility.

3. Distribution control - modify distribution facilities and controls to increase the reliability,

consistency and flexibility ofwater deliveries:

4. Reuse systems - construct facilities to capture and reuse District operational spills;

5. Incentive pricing - implement a pricing structure, such as tiered-block pricing, which promotes one

or more ofthe following goals: a) encouraging more efficient water use at the farm level, b)

supporting planned conjunctive use of groundwater, c) increasing groundwater recharge, d)

reducing problem drainage, and e) improved management ofenvironmental resources;

6. On-farm program incentives - facilitate and/or provide financial incentives and assistance for

improved on-farm water management;

7. Conjunctive use - increase planned conjunctive use ofsurface and groundwater within the District;

8. Land management - facilitate alternative uses for lands xvith exceptionally high water duties, or

whose irrigation contributes to significant problems;

9
9. Pump efficiency evaluations - coordinate the evaluation ofDistrict and private pumps with local

utilities, evaluating both energy and water efficiency;

10. Operational practices and procedures - evaluate potential District, state and federal policy and

institutional changes that could allow more flexibility in water delivery and carry-over storage.

Step 4. Best Management Practicesfor Maliicival and Indw<K.zl ~c~ii~c.i~rs

Intent:

To develop an implementation plan for urban Best Management Practices (BMPs) that have been proven to

accomplish improved (more efficient) water management.

Evaluation:

Some BMPs are considered “universally applicable” and others are considered “generally applicable.”

Reclamation recognizes that, under certain circumstances, the generally applicable practices may not make

sense for District implementation. Districts will implement each generally applicable BMP unless the District

provides adequate documentation for an exemption.

Detail Expected in an Adequate Plan:

This part ofthe plan identifies District-specific programs to accomplish the BMPs. It is understood that

programs developed by wholesale agencies may not be implemented at the retail customer level, except within

the District’s retail service area. For the purposes ofthese Criteria, the plan needs to describe the program that

the District thinks will best accomplish the practice. The development and implementation ofthe BMPs in a

wholesaler’s plan is the responsibility ofReclamation’s contractor.

The success ofsome ofthe practices will depend on cooperative work with other entities. It is recognized that

there may be constraints to successful implementation ofplanned programs. Monitoring and updating will

allow the District to modify any planned programs that do not accomplish the practice as designed.

A. Critical Best Management Practices for Municipal and Industrial Contractors

This section lists the BMPs that all Districts will implement or are already implementing. Provide a description

ofthe implementation plan and include time schedules, budgets and monitoring plans. Each District shall also

complete and submit the California Urban Water Conservation Council annual report form. Ifa BMP is to be

studied please provide details and schedules ofthe study.

1. Distribution system water audits, leak detection and repair

2. Metering with commodity rates for all new and existing connections

3. Landscape efficiency requirements for new/existing commercial, industrial, institutional,

governmental and multi-residential developments.

4. Public information

5. School education

6. New commercial, industrial and institutional water use review

7. Conservation pricing - water and sewer service

8. Water waste prohibition

9. Demand management staff

10. Financial incentives

10
B. Exemptible Best Management Practices for Municipal and Industrial Contractors

ch District shall develop a program to implement the following BMPs unless the District demonstrates that

practice does not make sense for the District to implement. Districts may spend time studying the most

effective way to implement a BMP or whether a BMP is appropriate for a District, For appropriate BMPs,

provide a description ofthe implementation plan and include time schedules, budgets and monitoring plans. Ifa

BMP is to be studied, provide details and schedules ofthe study. These studies must be completed

expeditiously and before the next Plan update. Districts should follow the exemption criteria (see Step 5) to

justify exemptions and provide the exemption in this Step. See Attachment B for examples ofcircumstances

under which BMPs are not applicable.

1. Interior and exterior water audits and incentive programs forsingle family residential, multi

family residential, and governmentallinstitutional customers

2. Plumbing, new & retrofit

3. Large landscape water audits and incentives

4. Commercial, industrial and institutional conservatioR..

5. Landscape water conservation for new and existing single family homes

6. Ultra lowflush toilet installation program

Step 5. Evemption Process

Intent:

in—. demonstrate in a clear and concise manner that a BMP is either not cost-effective, not financially feasible,

egal or not environmentally possible for a District to implement.

EvaIna tion:

These Criteria recognize that some BMPs are not appropriate or possible forsome Districts to implement. To

document an exemption provide the basis, rationale, and details for excluding a BMP; such documentation shall

address, as appropriate, cost-effectiveness, financial feasibility, and eQvironmental or legal constraints to BMP

implementation. Reclamation will consider exemption requests prepared using the final AB-3616 exemption

process.

Detail Expected in an Adequate Plan:

LEGAL CONSTRAINTS

In order to justify a BMP exemption because it would not be legal for the District to implement, detail the

following:

1. A list ofany known laws, regulations, court decisions, or other legal constraints that make it illegal for

the District to implement the BMP; and

2. A list ofthe stepsthat would be required to remove these constraints; and

3. A description ofwhat steps the District has taken to remove these constraints; and

4. Documentation of efforts by the District to work with other entities that would have the legal authority

to carry out the BMP within the District’s service area.

II
ENVIRONMENTAL CONSTRAINTS

In order to justify an exemption due to known adverse environmental impacts, the Plan must document the

critical environmental issues and known (qualitative andior quantitative) negative impacts ofthe BMP and an

explanation ofwhy effective mitigation ofthese impacts is not possible. If mitigation ofthe environmental

impacts is possible, the practice must be implemented unless it can be exempted by another exemption category.

For example, ifthe mitigation costs make the project economically infeasible, a discussion ofthe mitigation

plan and necessary mitigation costs should be included as a part ofthe economic analysis.

ECONOMIC CONSTRAINTS

In order to justify an exemption due to economic constraints, the Plan must document the following:

1. A benefit-cost analysis which demonstrates that the costs to the District outweigh the benefits to the District

over the life ofthe measure. Districts must perform the analysis by comparing the present value of all benefits

to the present value of all costs. Document the projected/estimated benefits and costs and the methodology for

analysis (benefits and costs should be quantified to the extent possible). Th~ analysis performed for each

excluded BMP (from the District perspective) must include, but is not limited to, the following benefits and

costs:

Benefits

• All capital costs avoided by the District which include, but are not limited to, the costs associated with

the development of new supplies (e.g., studies. construction, labor, etc.), transportation, and the required

increase in storage, distribution capacity, and wastewater facilities and treatment capacity, etc.,

• Operation and maintenance costs associated with the decrease in the production and distribution of watc

orthe treatment and disposal of wastewater which include, but are not limited to, energy, labor, treatment,

storage, drainage treatment and disposal, etc.,

• Water purchases avoided by the District,

• Environmental costs avoided by the District,

• Environmental enhancements,

• Revenues from other entities which include, but are not limited to, revenue from the sale ofwater made

available by the BMP, financial incentives received from other entities, etc.,

• Other benefitsto the District customers which include, but are not limited to, hydropower, improved

crop yields, improved crop quality, labor savings, fertilizer savings, increased farm income, etc..

Costs

• Capital expenditures incurred by the District for implementation ofthe BMP which include, but are not

limited to, equipment, supplies, materials, construction, etc.,

• Operation and maintenance costs to plan, design, implement, enforce, and evaluate the practice,

• Financial incentives to customers,

• Losses in revenues,

• Coststo the environment, and

• Other costs to the District.

Several accepted benefit-cost analysis methodologies exist (e.g., California Energy Commissions Integrated

Resource Planning Methodology, generally accepted accounting principles, etc.). Districts are considered to be

the best suited to evaluate their own economic situation with an al)propriate methodology.

12
2. A discussion and quantification, to the extent possible, of other benefits associated with the implementation

ofthe BMP that may be ofinterest to potential partners, but are not the direct sole responsibility ofthe District.

NANCIAL CONSTRAINTS

In order to adequatelyjustify an exemption due to financial constraints, the Plan must clearly document the

following:

1. The benefits and costs ofthe BMP to the District; and

2. The District funding needed to implement the cost-effective BMPs; and

3. A discussion regarding why th~ District cannot finance the BMP through rate adjustments, assessments,

etc.; and

4. A discussion ofthe District’s reasonable efforts to secure funding from other entities which include, but

arc not limited to, lending institutions and bonding authorities an~ an explanation of why these entities would

not provide funding; and

5. The required amount ofa grant or subsidy that would be needed to feasibly implement the BMP if

financing or partnerships could not be obtained. .

13
Attachm~nt A

Information required of Districts located in the drainage problem area

District’s included in the drainage problem area, as identified in A Management PlanforAgricultural

Subsuiface Drainage and Related Problems on the Westside San Joaquin Valley (‘September 1990), are listed,

by sub-area, below. Iffuture editions ofthe drainage report revise the boundaries ofthe drainage problem area

or other factors used to determine which districts are in the drainage problem area, Reclamation will revise

Attachn~ent A to conform with the current drainage report.

I. Reclamation districts in the Grasslands Subarea: Broadview WD, Central California ID, Del Puerto WD,

Firebaugh Canal WD, Mercy Springs WD, Pacheco WD, Panoche \VD, San Luis Canal Company, San Luis

WD.

2. Reclamation districts in the Westlands Subarea: James ID, Tranquillity ID and Westlands WD.

3. Reclamation districts in the Tulare Subarea: Alpaugh ID, Atwell Island WD, Lower Tule River ID, and

Pixley ID.

4. Reclamation districts in the Kern Subarea: Alpaugh ID.

Districts listed above shall describe which recommendations prescribed in A Management Planfor Ag,~icul/uraI

Subsw face Drainage and RelatedProblems on the Westside San .Joaquin Valley (‘September 1990) have been~

incorporated in their water conservation programs to improve conditions in drainage problem areas. These

recommendations include:

1. Source Control

~. Land Retirement

3. Drainage Water Treatment

4. Drainage Water Reuse

5. Shallow Groundwater Pumping

6. Evaporation Ponds

Provide a description and level of expenditure for each activity designed to address the recommendations ofthe

San Joaquin Valley Drainage Program. Identify how implementation ofthe recommendations has or will

substantially reduce deep percolation on drainage problem lands. Describe which recommendations have not

been implemented and why.

14
Attachment B

Non-Applicability (N/A) of Exemptible BMPs

establish that a BMP is not applicable to the District, the Plan should explain the reasons why the BMP does

.3pply to the District. This justification must be consistent with Step I ofthe Criteria titled, “Describe the

.

3trict.” Examples of non-applicability for each exemptible BMP are listed below. This list is not all

inclusive.

Step 3, B. Exemptible Best Management Practices for Agricultural Contractors

I. Distribution system lining/piping - NA could include: completely piped systems, unlined systems or

sections ofsystems which are used as part ofa planned conjunctive use program;

2. Regulatory reservoirs - NA could include: completely piped systems which do not have delivery

constraints;

3. Distribution control - NA could include: completely piped systems ~vhichdo not have delivery

constraints;

4. Reuse systems - NA could include: completely piped systems which do not have delivery constraints;

5. Incentive pricing - None identified;

6. On-farm plogranl incentives - None identified;

7. Conjunctive use - NA could include: districts which do not overlie a useable ground water basin and thus

neither the district nor its customers pump or use ground water;

8. Land management — NA could include: districts without irrigable lands that have exceptionally high water

duties or whose irrigation does not contribute to significant problems;

9. Crop & field - NA could include: districts where are least 50 percent ofthe customers irrigate crops with

non—district water;

I” Pump efficiency evaluations - NA could include: districts where neither the district nor its customers use

.round water pumps, lift pumps, pressrire pumps, filter pumps, etc.;

~)perational practices and procedures - None identified.

Step 4, B. Exernptible Best Management Practices for Municipal and Industrial Contractors

I. Interior and exterior water audits and incentive programs for ~ingle family residential, multifamily

residential, and governmentallinstitutional customers - None identified.

2. Plumbing, new & retrofit - NA could include: districts which supply water only to ~structureswhich have

no plumbing fixtures or supply water only for exterior uses.

3. Large landscape water audits and incentives - NA could include: districts which do not supply water to

any landscape ofthree acres or more.

4. Commercial, industrial and institutional conservation - NA could include: districts which provide water

only to residential customers.

5. Landscape water conservation for new and existing single family homes - NA could include: districts

which provide no water to residential customers.

6. Ultra low flush toilet replacement - None identified

15