Westlands Water District 

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

February 19, 2014 

Ms. Michelle Denning 

Regional Planning Officer 

Bureau of Reclamation, MP-30oo 

2800 Cottage Way 

Sacramento, CA 95825 

Subject: Comments on the Delta-Mendota CanaVCalifornia Aqueduct (DMC/CA) Intertie 

Repayment Analysis Report 

Dear Ms. Denning: 

Westlands Water District (District) has received and reviewed the De~a-Mendota 

CanaVCalifomia Aqueduct (DMC/CA) Intertie Repayment Analysis Report dated January 30, 

2014. Of the repayment alternatives presented in this Report, the District supports Option 1 

because it is the only choice that adheres with the original project purpose, com plies with the 

legislative authority (PL 108-361) and Record of Decision (ROD), and is consistent with the 

direction that the Central Valley Project (CVP) be a fully integrated project both operationally 

and financially. . 

The purpose of the Intertie project was to restore the conveyance capacity of the Delta-Mendota 

Canal (DMC) so that Jones Pumping Plant (JPP) could operate at full capacity. Conveyance 

capacity on the DMC had been reduced because of subsidence. The overall cost of 

rehabilitating the DMC was prohibitive. The Intertie project was introduced as a more cost 

effective way to restore the conveyance capacity of the DMC so that JPP could operate at full 

capacity. If the costly rehabilitation of the DMC had occurred, there would be no discussion 

regarding repayment altematives; the costs associated with that rehabilitation would be included 

in the Conveyance Cost Pool. 

The legislative authority and the ROD both state that the purpose of the project is to fix th.e 

conveyance problem on the DMC. Section 1.3 of the Record of Decision states: 

''The purpose of the Proposed Action is to improve the DMC conveyance conditions that 

restrict the Jones Pumping Plant to less than the original design pumping capacity of 

4,600 CFS and to improve flexibility for operations and maintenance and emergency 

activities: 

This clearly articulates that the primary purpose of the Intertie project was related to conveyance 

in the DMC. If the more costly solution to address this problem, rehabilitating the canal, had 

been undertaken there would be no question about the cost allocation going to the Conveyance 
February 19, 2014 

Page 2 

Cost Pool. Implementing a more cost effective solution (Le., construction of the Intertie) should 

not bear upon or alter this outcome. 

Additionally, Option 1 is also the only option that supports the basic proposition that the CVP be 

integrated both operationally and financially. Allocation of costs based upon quantifiable 

benefits is not consistent with other CVP conveyance facilities and is not in alignment with the 

direction that the CVP be a fully integrated project. Furthermore, since the Bureau of 

Reclamation's ability to satisfy its obligations to the Exchange Contractors and the Refuges is 

improved by the construction and operation of the Intertie, the benefits should not be COnfined to 

the results of the CALSIM model. By including the Intertie in the Conveyance Cost Pool, 

Reclamation would align itself with prior methodologies and direction from authOrizing 

legislation. 

Notwithstanding the District's support of Option 1 as the only appropriate choice presented in 

the Report, we would support evaluation of a fourth option. During the conference call on 

February 11, 2014, Dana Jacobsen of Santa Clara Valley Water District re-introduced the option 

of allocating costs for the Intertie based upon the allocation of capital costs for JPP. It should be 

noted that during the planning phase for the Intertie project, this was the agreed upon approach 

by the funding participants and Reclamation. 

Please contact Mr. Stephen Farmer at 559-241·6240 or sfarmer@westlandswater.org if you 

have any questions or require any additional informatlon. 

Sincerely. 

~tJ/.l-rThomas W. Birmingham 

General Manager 

cc: Brenda Bryant 

Asst. Regional Director for Business Services 

Autumn Wolf 

Regional Financial Manager 

David Murillo 

Regional Director