Westlands Water District 

3130 N. Fresno Street, P.O. Box 6056, Fresno, California 93703-6056, (559) 224-1523, FAX (559) 241-6277 

July 23, 2014 

Bureau of Reclamation Mid-Pacific Region 

Ms. Autumn Wolfe 

Acting Regional Financial Manager, MP-3000 

2800 Cottage Way 

Sacramento, CA 95825 

Dear Ms. Wolfe, 

Westlands Water District (District) attended Reclamation's June 23, 2014 workshop on 

Municipal and Industrial (M&I) Ratesetting Policy. The workshop coVered proposed 

policy revisions and policy finalization schedule. 

The District submitted comments to Reclamation's May 21, 2012 workshop on the same 

topic in July 2012. The District appreciates Reclamation's consideration of its several 

points discussed at the June 23, 2014 workshop. Most notable are the omission of the 

$15.00 minimum rate, the clarified definition of a Long Term Contractor and repayment 

order revised to be consistent with the Irrigation Ratesetting Policy. 

The following comments pertain to the Draft M&l Ratesetting Policy distributed at the 

June 23, 2014 workshop. 

1. The District understands from discussions occurring durjng the June 23, 2014 

workshop that the revised M&l Ratesetting Policy attempts to be "in line with the 

Irrigation Ratesetting Policy (1988) as much as possible" (Mr. J. Reynoso). It is 

further understood that no changes to the Irrigation Ratesetting Policy will occur 

as a carry over from this revision and finalization process to the M&l Ratesetting 

Policy. 

2. In the first paragraph of the Description of Water Rate Components section on 

page 6 it is noted that there is to be included a general description of each of the 

M&l water rate components, computational mechanics and other specifics. 

However, on page 7, in the conveyance paragraph the computational mechanics 

appear to have been omitted~ The District requests that this be corrected in the 

final version and that it be kept "in line with the Irrigation Ratesetting Policy." 

3. Grammatical errors include: (1.) Page 3 first paragraph includes a repeated word 

"the the," (2.) Page 4 third paragraph has a misspelled word "rateseting" should 

be "ratesetting," (3.) Page 12 Water Rate or Rate(s) definition has two misspelled 

words: "cocument" should be "document" and "workds" should be "words." 

4. The Draft M&l Ratesetting Policy interchangeably uses the words or phrases: 

investment, plant-in-service investment, plant investment; construction costs, 
Ms. Autumn Wolfe 

Page 2 

July 23, 2014 

capital, and M&l plant cost. Keeping in line with the migration away from 

reference to "capital" to the phrase "construction cost" Reclamation could update 

this policy accordingly. Adding a definition for "Construction Cost" to the glossary 

would add clarity to this term. 

5. The initial reference to "O&M" is at the top of page 4, "as well as allocable 

operation and maintenance expenses." This should be revised to "as well as 

allocable operating and maintenance (O&M) expenses" and further references to 

operating cost, operating expenses or operating and maintenance costs or 

expenses should be revised to simply "O&M." 

The District values the opportunity to review and comment on the Draft M&l Ratesetting 

Policy and anticipates that the opportunity to review and comment continues throughout 

the finalization process. Please contact Mr. Steve Farmer for assistance in this matter at 

(559) 241-6240 or sfarmer@westlandswater.org. 

Sincerely, 

Bobbie Ormonde 

Director of Finance and Administration 

Attachment 

cc: Jesus Reynoso 

MP Region Acting Ratesetting Supervisor