Westlands Water District 

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

December 30, 2013 

Michelle Denning 

Regional Planning Officer 

Bureau of Reclamation, MP-3000 

2800 Cottage Way 

Sacramento, CA 95825 

Subject: Westlands WD Objection to Delta-Mendota Canal/California Aqueduct Intertie 

Cost Allocation Information Report. 

Dear Ms. Denning: 

Westlands Water District (District) has received and reviewed the DMC/CA Intertie Cost 

Allocation Information Report dated December 2013. The District was also in attendance at the 

DMC/CA Intertie Cost Allocation briefing on December 12, 2013 at the USSR office in 

Sacramento. The District objects to the adoption of the decisions in the report based on the 

original project purpose, the methodology used in the report, and Article 19(a) of the Interim 

water supply contract between the United States and the District. 

The original project purpose as listed in the 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 that the original design pumping capacity of 

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

activities. " 

That very clearly states that the purpose of the Intertie project is first and foremost, to improve 

conveyance in the DMC. With that, it is the District's assertion that the allocation of costs of the 

Intertie must be to the Conveyance Cost Pool. 

The methodology used to allocate costs in the Cost Allocation Information Report is not 

consistent with any other cost allocation of CVP facilities. Allocation of costs based upon 

quantifiable benefits is not consistent with the other CVP projects and is not in alignment with 

the direction that the CVP be a fully integrated project both operationally and financially. By 

including the DMC/CA Intertie in the Conveyance Cost Pool, Reclamation would realign itself 

with prior methodologies and direction from authorizing legislation. Please consider this 

objection as pertaining to the Draft 2014-15 Rates which we are responding to in the 60 day 

window from their release on October 31 , 2013. 
December 26,2013 

Page2 

Lastly, Article 19(a) of the interim water supply contract between the United States and the 

District states, 

"In order to further their mutual goals and objectives, the Contracting Officer and 

the Contractor shall communicate, coordinate, and cooperate with each other, and with 

other affected Project Contractors, in order to improve the operation and management of 

the Project. The communication, coordination , and cooperation regarding operations and 

management shall include, but not be limited to, any action which will or may materially 

affect the quantity or quality of Project Water supply, the allocation of Project Water 

supply, and Project financial matters including, but not limited to, budget issues. The 

communication, coordination, and cooperation provided for hereunder shall extend to all 

provisions of this Contract. Each party shall retain exclusive decision making authority 

for all actions, opinions, and determinations to be made by the respective party." 

The allocation of Intertie's costs is certainly an "action which will or may materially affect .. 

Project financial matters including, .. . " and is subject to the provisions of Article 19(a); however, 

despite prior requests to the preceding Contracting Officer, there has been no communication 

between Reclamation and Westlands on this issue. I am informed that the issue has been the 

topic of discussions between Reclamation and the Central Valley Project Water Association, but 

communications with the CVPWA is not communications with Westlands. Article 19(a) is a 

provision of a contract between the United States and Westlands, and Westlands expects that 

the United States will abide by the terms of the contract. 

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

you have any questions or require any additional information. 

Sincerely, 

Bobbie Ormonde 

Director of Finance and Administration 

Cc: Ms. Katherine Thompson 

Asst. Regional Director for Business Services 

Brenda Bryant 

Regional Financial Manager 

David Murillo 

Regional Director