Ms. Autumn Wolfe 

Ratesetting Manager 

Bureau of Reclamation 

2800 Cottage Way 

Sacramento, CA 95825-1898 

Dear Ms. Wolfe: 

Western Area Power Administration (Western) appreciates the opportunity to provide comments 

regarding the repayment options which were presented and discussed at the February 11, 2014, 

Public Workshop for the Delta-Mendota Canal/California Aqueduct Interne (Interne) Project. 

Western seeks an outcome which is: (I) equitable, (2) consistent with project authorization and 

existing and long-term repayment policy, (3) allocates costs to the intended beneficiaries, and (4) 

assures long-term sustainability of the Central Valley Project (CVP). 

Western remains concerned that the CVP's accomplishments continue to steadily decline over 

time as a result of both environmental and other physical constraints, due to initiatives such as 

Central Valley Project Improvement Act Restoration Fund activities, Delta activities, and 

designation of new project use loads, and their impact on the price competitiveness of the 

hydropower function. While the Intertie project increases water supply by 28,000 acre feet, 

commercial power receives no benefit and in fact output is reduced because of increased 

conveyance pumping load and potentially for pumping not fully reimbursed related to nonproject water conveyance. Futhermore, Reclamation and its water contractors have been 

designing and discussing this project for many years, and the representations and assumption 

when this project was approved by Congress was the costs for the project would be allocated to 

water users. In that regard, Western supports Option 2 which allocates the Interne costs to the 

conveyance pumping cost component and recovers costs according to cost distribution specific to 

the water beneficiaries. Western recommends Option 2 because: 

(1) The proposed allocation supports and is consistent with a long-term and wellestablished repayment policy, thus, would be imprudent to deviate from that policy; 

(2) When Reclamation sought authorization for this project, it was contemplated the 

project would be an operation, maintenance, and replacement activity funded by the 

water beneficiaries (in fact, the water users had advanced funded over $20 million to 

Reclamation prior to the Congressional appropriations under the American Recovery and 

Reinvestment Act). 

(3) The proposed allocation is consistent with the operatioi1al conveyance pumping 

scenarios previously defined in the Record of Decision (ROD); 

Department of Energy 

Western Area Power Administration 

Sierra Nevada Customer Service Region 

114 Parkshore Drive 

Folsom, California 95630-4710 

FEB 1 9 Z014 
(4) As stated in the Cost Allocation Report, the purpose of the Intertie is to improve the 

Delta Mendota Canal conveyance conditions that restrict the Jones Pumping Plant. 

Additionally, the ROD states that the primary project component of the Intertie would be 

a pumping plant; 

(5) The Cost Allocation Report also states that the Intertie was conceived initially by the 

San Luis and Delta-Mendota Water Authority and member districts to improve the water 

supply reliability of the CVP deliveries south of the Delta; 

(6) The inequity resulting from a change to the initial cost assignment after project 

completion, as is the case with Options 1 and 3, inadvertently assigns costs to power and 

could result in potential increases in irrigator's ability to repay, which under Reclamation 

law are reassigned to the preference power users for repayment; and, 

(7) Lastly, revising a cost allocation after project completion, without the benefit of 

public comments before project development, allows project beneficiaries to potentially 

change the alignment of factors and criteria used to justifY the project from those whom 

are ultimately responsible for repayment. 

For the above reasons, it is inequitable and improper to change the cost allocation to assign 

project costs to CVP power users. Western believes that the criteria should be consistent through 

the project's life cycle in order to assure consistency, accuracy, and equity. You may contact 

Regina Rieger at (916) 353-4629 if you need clarification on Western's comments. 

Sincerely, 

~~ Power Marketing Manager