Katarina Buelna

Westlands Water District

3130 N. Fresno Street, P.O. Box 6056 

Fresno, CA 93703

559 241-6226 kbuelna@westlandswater.org

November 1, 2013

Ms. Miller-Levy,

After attending the May 17 Cost Allocation meeting focusing on water supply, listed below are Westlands comments 

and inquires: 

• During the presentation of the single purpose model, the presenter and power point presentation failed to 

include recreation. Since recreation activities impacts are considered in environmental documents and 

recreation activities generate revenue, a single purpose use model should be analyzed for recreation at 

facilities where current legislation allows it. 

• As you are aware the current BiOp’s affecting Delta Operations are under review and CalSim2 does not 

incorporate the future regulatory changes. Since this future regulatory change is known, it would be 

inaccurate to develop a new cost allocation with incorrect information. 

• How will the single purpose sizing model account for the exchange contractors’ allocation because their 

allocation is dependent on inflow into Shasta not reservoir storage? 

See attachment A. 
Attachment	A:	Cost	Allocation	Comments	

• On slide 7 of the power point presentation, it states that conveyance and pumping facilities only 

serves the water supply purpose. This statement suggests that only agricultural and municipal 

and industrial contractors will be allocated costs associated with conveyance and pumping 

facilities, which is not correct. There are fish and wildlife refuges south of the Delta who divert 

water from the San Luis Canal (SLC). As you may recall, Jones Pumping Plant lifts water from the 

Delta into the Delta Mendota Canal and conveys water to the Mendota Pool, San Luis Reservoir 

and the SLC. Hence, conveyance and pumping facilities are required for multi-purpose uses not 

only water supply purpose. Fish and wildlife refuges have a higher priority than agricultural 

service contractors. 

• According the methodology presented on May 17, the single purpose model will generate the 

total amount of water storage required for each individual reservoir. Currently the same 

molecule of water is used for multiple purposes. How will Reclamation account for the overlap? 

o For Example, in the fall Shasta’s storage is required to meet a cold water pool of 1.9 

MAF; this same water which is required for cold water pool storage is potentially 

released later for the benefit of temperature, water supply, water quality and 

hydropower generations. Once the sizing model is complete for all possible single 

purposes, because of overlap the sum of all uses will make each reservoir larger than it 

currently is. How is the overlap being accounted for in the allocation of costs? 

• Will there be a technical, or select customer, review with an opportunity for comment on the 

details utilized and resulting CALSIM2 hydrology and delivery modeling prior to single purpose 

size modeling? 

• In the presentation for public meeting #1 held on October 1, 2010 the evaluation phase of the 

project is scheduled to commence in years 4 to 5 of the study. Will this evaluation stage include 

customer testing and review of the results of the SCRB analysis for each facility and beneficiary? 

Thank you for the opportunity to provide comments to the United States Bureau of Reclamation in this 

matter, if you have any additional questions please feel free to contact Katarina Buelna at 559- 241-

6226.