Samuel W. Bodman

March 31, 2006 Page 2


### Implementation of state water efficiency standards will result in significant reduction in use and cost to pump, treat and provide reliable state water supplies while also reducing energy consumption and costs required to maintain and operate water delivery systems and wastewater treatment facilities. The amount of energy that will be conserved as a result of water efficiency standards will be significant. A fully implemented 8.5 water factor standard will save as much energy as the annual usage for approximately 50,000 California homes, and the 6.0 water factor will save the equivalent annual energy use of approximately 85,000 California homes. Along with increased consumer energy and water cost savings, these water efficiency standards would not burden the. clothes washer industry. Instead, these standards would positively impact the manufacturing, marketing, distribution, sale and servicing of these high-efficiency washers. Today, most appliance manufacturers, large and small, already produce these types of high efficiency washers and comply with proposed standards. While 30% of California's sales of washers already comply with the 8.5 standard, 20% of sales already comply with the 6.0 standard. Various rebate incentive and educational programs throughout the state are also in place to support and increase the sale of these washers and currently account for 39% of the market. However, if provided this preemptive waiver, California can achieve a 100% market share and increase sales competition and gross revenue of the clothes washer industry. As California uses more water than any state and will continue rapid population growth, we support a residential clothes washer water efficiency standard of 8.5 effective January 1, 2007 followed by a 6.0 standard effective January 1, 2010 to conserve and manage supplies for a growing population. Implementation of these standards will create tremendous water and energy savings for the region while supporting legal obligations to reduce use of imported water deliveries. It is crucial that California carry out these water efficiency standards and responsibly reduce its dependence on overly tapped and energy-intensive regional and imported water supplies. Water efficiency standards for residential clothes washers will help California achieve this goal. We sincerely hope you will approve the Petition to Exempt from Preemption California's Water Efficiency Standards for Residential Clothes Washers. It is critical to the state's economy and quality of life for those who will make California their home for generations to come. Sincerely,

William A. Baker President

17140 S. Avalon Blvd ® Suiic 210 • Carson. Cry 90746-1296
Radcd OO25pi

# Cucamonga Valley

Water District

Robert A

. DeLoach General Manager Chief Executive Officer



### March 30, 2006

Samuel W

. Bodman Secretary of Energy United States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 10440 Ashford Street ® Rancho Cucamonga , CA 91729-0638 P.O. BOX 638 ® (909) 987-2591 . Fax (909) 476-8032



### Re: Support for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers - Docket #EE-RM-PET- 100 Dear Mr. Secretary: On behalf of Cucamonga Valley Water District we strongly urge you to approve the Petition to Exempt from Preemption California's Water Efficiency Standards for Residential Clothes Washers. California's water use is intricately linked to high energy costs and consumption. As the nation's largest water user with a vast water transportation infrastructure, California's water systems are uniquely energy-intensive due to pumping requirements to deliver volumes of water long distances, across mountain ranges and over high elevations. The State Water Project, the nation's largest state-built water conveyancesystem of reservoirs, lakes, power plants, pump stations, canals, tunnels and a 444 milelong aqueduct, is the largest single user of electricity in the state. The amount of energy required to support the state's water delivery system and energy requirements associated with treating, pumping and delivering water from water supply sources to population centers is of increasing concern throughout the state. It is clear that more efficient water use will substantially reduce energy costs and use.



## 0000260

Jamee V. curatelo, Jr. R. Robert NWW Jerome IS1l. Wi lson Randal l Ja mes Reed KAV 71e98 DirecilorSupport for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers

- Docket #EE-RPMPET-100 3/30/2006 Page 2

Due to the state's unique water and energy circumstances , California must pursue highly efficient and cost-effective energy and water conservation strategies and solutions. In 2002, the California State Legislature declared that " a significant portion of urban water demand in the state is for residential clothes washers " and that "water conservation is a proven tool that will make the most effective use of the state's limited supply, and will conserve energy ." As a result of these declarations, the California Energy Commission adopted water efficiency standards for residential clothes washers to address the unique and compelling interests and needs of California. 

### Implementation of state water efficiency standards will result in significant reduction in use and cost to pump, treat and provide reliable state water supplies while also reducing energy consumption and costs required to maintain and operate water delivery systems and wastewater treatment facilities

. The amount of energy that will be conserved as a result of water efficiency standards will be significant . A fully implemented 8.5 water factor standard will save as much energy as the annual usage for approximately 50,000 California homes, and the 6

.0 water factor will save the equivalent annual energy use of approximately 85,000 California homes. Along with increased consumer energy and water cost savings, these water efficiency standards would not burden the clothes washer industry. Instead, these standards would positively impact the manufacturing , marketing, distribution, sale and servicing of these high efficiency washers

. Today, most appliance manufacturers, large and small , already produce these types of high efficiency washers and comply with proposed standards

. While 30 percent of California ' s sale of washers already comply with the 8

.5 standard , 20 percent of sales already comply with the 6.0 standard

. Various rebate incentive and educational programs throughout the state are also in place to support and increase the sale of these washers and currently account for 39 percent of the market

. However, if provided this preemptive waiver, California can achieve a 100 percent market share and increase sales competition and gross revenue of the clothes washer industry.
As California uses more water than any state and will continue rapid population growth, we support a residential clothes washer water efficiency standard of 8.5 effective January 1, 2007 followed by a 6. 0 standard effective January 1, 2010 to conserve and manage supplies for a growing population

. Implementation of these standards will create tremendous water and energy savings for the region while supporting legal obligations to reduce use of imported water deliveries

. It is crucial that California carry out these water efficiency standards and responsibly reduce its dependence on overly tapped and energyintensive regional and imported water supplies. Water efficiency standards for residential clothes washers will help California achieve this goal.



## 0000261Support for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers

- Docket #EE

-RM-PET-100 3/30/2006 Page 3
We sincerely hope you will approve the Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers

. It is critical to the state 's economy and quality of life of populations that will make California their home for generations to come. 

### Sincerely,

Jo Lynne Russo

-Pereyra Assistant General Manager for External Affairs



# 00002CM999 RUSH CREEK PLACE • POST OFFICE BOX 146 • NOVATO, CALIFORNIA 94948 • 015) 897-4133 • FAX 1415) 892-8043



### March 28, 2006

Samuel W. Bodman Secretary of Energy United States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Re: Support for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers (Docket Number: EE-RM-PET-100)

Dear Mr. Secretary: On behalf of North Marin Water District, we strongly urge you to approve the Petition to Exempt from Preemption California's Water Efficiency Standards for Residential Clothes Washers. California's water use is intricately linked to high energy costs and consumption. As the nation's largest water user with a vast water transportation infrastructure, California's water systems are uniquely energy-intensive due to pumping requirements to deliver volumes of water long distances, across mountain ranges and over high elevations. The State Water Project, the nation's largest state-built water conveyancesystem of reservoirs, lakes, power plants, pump stations, canals, tunnels and a 444 milelong aqueduct, is the largest single user of electricity in the state. The amount o[ energy required to support the state's water delivery system and energ} requirements associated with treating, pumping and delivering water from water supply sources to population centers is of increasing concern throughout the state. It is clear that more efficient water use will substantially reduce energy costs and use. Due to the state's unique water and energy circumstances, California must pursue highly efficient and cost-effective energy and water conservation strategies and solutions. In 2002, the California State Legislature declared that "a significant portion of urban water demand in the state is for residential clothes washers" and that "water conservation is a proven tool that will make the most effective use of the state's limited supply, and will conserve energy." As a result of these declarations, the California Energy Commission adopted water efficiency standards for residential clothes washers to address the unique and compelling interests and needs of California.


## 0000263Implementation of'state water efficiency standards will result in significant

reduction in use and cost to pump , treat and provide reliable state water supplies while also reducing energy consumption and costs required to maintain and operate water delivery systems and wastewater treatment facilities

. The amount of energy that will he conserved as a result of water efficiency standards will he significant . A fully Itill) Ieniented 8.5 water factor standard will save as much energy as the annual usage for approximately 50,000 California homes, and the 6.0 water factor will save the equivalent annual energy use of approximately 85,000 California homes. Along with increased consumer energy and water cost savings, these water efficiency standards would not burden the clothes washer industry. Instead, these standards would positively impact the manufacturing, marketing, distribution, sale and servicing of these high efficiency washers. Today, most appliance manufacturers, large and small, already produce these types of high efficiency washers and comply with proposed standards. While 30 percent ofCalifornia's sale of %,ashers already comply with the 8.5 standard, 20 percent of sales already comply with the 6.0 standard. Various rebate incentive and educational programs throughout the state are also in place to support and increase the sale of these washers and currently account for 39 percent of the market. However, if provided this preemptive waiver, California can achieve a 100 percent market share and increase sales competition and gross revenue of the clothes washer industry. As California uses more water than any state and will continue rapid population growth, we support a residential clothes washer water efficiency standard of 8.5 effective January 1, 2007 followed by a 6.0 standard effective January 1, 2010 to conserve and manage supplies for a growing population

. Implementation of these standards will create tremendous water and energy savings for the region while supporting legal obligations to reduce use of imported water deliveries. It is crucial that California carry out these waterefficiency standards and responsibly reduce its dependence on overly tapped and energyintensive regional and imported water supplies. Water efficiency standards for residential clothes washers will help California achieve this goal. We sincerely hope you will approve the Petition to Exempt From Preemption C'alilornia's Water l:fficiencv Standards for Residential Clothes Washers. It is critical to the state's economy and quality of life of populations that wil I make California their home for generations to come. Sincerely.

Chris DeGabriele, General Manager North Marin Water District

,ercer 51 a Ier ( ' nn.crea rnuu I cllcr In I'ul'Iic I Cr I.IjIIun Sup purl I encr. Suppun I.cUCr or W a IN er 030(, d.u



## 0000264

# CALIFORNIA 1

# '1'6.UNICIPAL UTILITIES i"^I CS

# OCIATION

915 L STREET, SUITE 1460 o SACRAMENTO, CALIFORNIA 95814 (916) 326

-5800 a FAX (916) 326

-5810 o www.cmua.org
JERRY JORDAN, Executive Director

OFFICERS
President MARCIE L. EDWARDS

Anaheim Vice President ALLEN SHORT Modesto Irrigation District

Secretary Vacant Treasurer JOSEPH F. H5U

Azusa General Counsel ARLEN ORCHARD Sacramento Municipal Utility District BOARD OF GOVERNORS

FRANK BELOCK San Diego DAVID A. BRENINGER Placer County Water Agency BILL D

. CARNAHAN So. California Public Power Authority

RICK COLEMAN Trinity public Utilities District

PHY W S E

. CURRIE

Pasadena RONALD DAVIS Burbank RONALD DEATON Los Angeles JAMES C. FEIDER

Redding DUANE GEORGESON Metropolitan Water District of Southern California JUNONA A. JONAS Santa Clara SUSAN LEAL San Francisco JAMES H. POPE Northern California Power Agency

JAN SCHORI Sacramento Municipal Utility District 

### March 28, 2006

Samuel W. Bodman Secretary of Energy United States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Re: Support for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers Dear Mr. Secretary: The California Municipal Utilities Association (CMUA) urges your approval of the Petition to Exempt from Preemption California ' s Water Efficiency Standards for Residential Clothes Washers.
California' s water use is intricately linked to high energy costs and consumption

. As the nation ' s largest water user with a vast water transportation infrastructure , California' s water systems are uniquely energyintensive due to pumping requirements to deliver volumes of water long distances, across mountain ranges and over high elevations. CMUA has long supported technological means of accomplishing energy and water conservation and has twice successfully sponsored California legislation lowering the water consumption of toilets in new construction

. Such improved standards accomplish meaningful conservation without relying on lifestyle changes of consumers. Implementation of state water efficiency standards will result in significant reduction in use and cost to pump, treat and provide reliable state water supplies while also reducing energy consumption and costs required to MIKE WALLIS East Bay Municipal Utility District 

### maintain and operate water delivery systems and wastewater treatment

GLENN STEIGER Imperial Irrigation District

JOHN ULRICH Palo Alto

KEVIN L WATTIER Long Beach 

### LARRY Turlock I

### rrigation W District 

### standard will save as much energy as the annual usage for approximately
DAVID H

. WRIGHT

Riverside 

### facilities. The amount of energy that will be conserved as a result of water .efficiency standards will be significant. A fully implemented 8.5 water factor 50,000 California homes, and the 6.0 water factor will save the equivalent annual energy use of approximately 85,000 California homes.

An organization for the protection of municipally owned utilities.
CMU.A. members provide utilityservice to mwe than 70% of the people of California.

### Samuel W. Bodman

March 28, 2006 Page 2

We sincerely hope you will approve the Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers. It is critical to the state's economy and quality of life of populations that will make California their home for generations to come.

cc: California Energy Commissioners



# 00002E;6BOARD OF DIRECTORS Brian Bowcock David D . De Jesus Dan Horan Luis M . Juarez Bob Kuhn Fred Lantz Joseph T. Ruzicka 

### March 28, 2006 GENERAL MANAGER/CHIEF ENGINEER Richard W. Hansen, P.E.

Samuel W. Bodman Secretary of Energy United States Department of Energy 1000 Independence Avenue, SW Washington , DC 20585 Re: Support for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers
Dear Mr

. Secretary:
On behalf ofThree Valleys Municipal Water District, we urge you to approve the Petition to Exempt from Preemption California 's Water Efficiency Standards for Residential Clothes Washers.
California ' s water use is intricately linked to high energy costs and consumption. As the nation ' s largest water user with a vast water transportation infrastructure, California ' s water systems are uniquely energy

-intensive due to pumping requirements to deliver volumes of water long distances , across mountain ranges and over high elevations

. The State Water Project , the nation's largest state

-built water conveyance system of reservoirs , lakes, power plants, pump stations , canals, tunnels and a 444 milelong aqueduct, is the largest single user of electricity in the state

. The amount of energy required to support the state ' s water delivery system and energy requirements associated with treating, pumping and delivering water from water supply sources to population centers is of increasing concern throughout the state

. It is clear that more efficient water use will substantially reduce energy use, and therefore costs.
Due to the state ' s unique water and energy circumstances , California must pursue highly efficient and cost

-effective energy and water conservation strategies and solutions. In 2002 , the California State Legislature declared that "a significant portion of urban water demand in the state is for residential clothes washers " and that "water conservation is a proven tool that will make the most effective use of the state's limited supply, and will conserve energy." As a result of these declarations, the California Energy Commission adopted water efficiency standards for residential clothes washers to address the unique and compelling interests and needs of California.

1021 E. Miramar Avenue o Claremont, California 91711-2052 Telephone (909) 621 -5568 e Fax (909) 625-5470 o http://www

. threevalleys.comSamuel W. Bodman March 28, 2006 Page 2

Implementation of state water efficiency standards will result in significant reduction in use and costs to pump , treat and provide reliable water supplies while also reducing energy consumption and costs required to maintain and operate delivery systems and wastewater treatment facilities

. The amount of energy that will be conserved as a result of water efficiency standards will be significant . A fully implemented 8.5 water factor standard for clothes washers will save as much energy as the annual usage for approximately 50,000 California homes , and the 6.0 water factor will save the equivalent annual energy use of approximately 85,000 California homes. Along with increased consumer energy and water cost savings, these water efficiency standards would not burden the clothes washer industry. Instead, these standards would positively impact the manufacturing, marketing, distribution, sale and servicing of these high efficiency washers. Today, most appliance manufacturers, large and small, produce these types of high efficiency washers and comply with proposed standards. While 30 percent of California's sale of washers already comply with the 8.5 standard, 20 percent of sales already comply with the 6.0 standard. Various rebate incentive and educational programs throughout the state are also in place to support and increase the sales of these washers and currently account for 39 percent of the market. As California uses more water than any state and will continue rapid population growth, we support a residential clothes washer water efficiency standard of 8.5 effective January 1, 2007 followed by a 6.0 standard effective January 1, 2010 to conserve and manage supplies for a growing population. Implementation of these standards will create tremendous water and energy savings for the region while supporting legal obligations to reduce use of imported water deliveries. It is crucial that California carry out these waterefficiency standards and responsibly reduce its dependence on overly tapped and energyintensive imported water supplies. Water efficiency standards for residential clothes washers will help California achieve this goal. We sincerely hope you will approve the Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers. It is critical to the state's economy and quality of life of populations that will make California their home for generations to come.

General Manager



# 000 0 

# 2Gh

# Santa Fe Irrigation District

POST OFFICE BOX 409 RANCHO SANTA FE, CALIFORNIA 92067-0409

(858) 756-2424 FAX (858) 756-0450

March 21, 2006

Samuel W. Bodman Secretary of Energy United States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Re: Support for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers, Docket number EE-RM-PET-100 Dear Mr. Secretary: On behalf of Santa Fe Irrigation District, we strongly urge you to approve the Petition to Exempt from Preemption California's Water Efficiency Standards for Residential Clothes Washers.
California' s water use is intricately linked to high

-energy costs and consumption. As the nation' s largest water user with a vast water transportation infrastructure, California' s water systems are uniquely energy-intensive due to pumping requirements to deliver volumes of water long distances , across mountain ranges and over high elevations

. The State Water Project, the nation ' s largest state

-built water conveyance system of reservoirs, lakes, power plants, pump stations, canals, tunnels and a 444 milelong aqueduct, is the largest single user of electricity in the state

. The amount of energy required to support the state ' s water delivery system and energy requirements associated with treating, pumping and delivering water from water supply sources to population centers is of increasing concern throughout the state

. It is clear that more efficient water use will substantially reduce energy costs and use.
Due to the state' s unique water and energy circumstances, California must pursue highly efficient and cost-effective energy and water conservation strategies and solutions. In 2002, the California State Legislature declared that "a significant portion of urban water demand in the state is for residential clothes washers" and that "water conservation is a proven tool that will make the most effective use of the state ' s limited supply, and will conserve energy ." As a result of these declarations, the California Energy



## 0 000269

### Commission adopted water efficiency standards for residential clothes washers to address

the unique and compelling interests and needs of California. Implementation of state water efficiency standards will result in significant reduction in use and cost to pump, treat and provide reliable state water supplies while also reducing energy consumption and costs required to maintain and operate water delivery systems and wastewater treatment facilities. The amount of energy that will be conserved as a result of water efficiency standards will be significant. A fully implemented 8.5 water factor standard will save as much energy as the annual usage for approximately 50,000 California homes, and the 6.0 water factor will save the equivalent annual energy use of approximately 85,000 California homes. Along with increased consumer energy and water cost savings, these water efficiency standards would not burden the clothes washer industry. Instead, these standards would positively impact the manufacturing, marketing, distribution, sale and servicing of these high efficiency washers. Today, most appliance manufacturers, large and small, already produce these types of high efficiency washers and comply with proposed standards. While 30 percent of California' s sale of washers already complies with the 8.5 standard, 20 percent of sales already comply with the 6.0 standard. Various rebate incentive and educational programs throughout the state are also in place to support and increase the sale of these washers and currently account for 39 percent of the market. However, if provided this preemptive waiver, California can achieve a 100 percent market share and increase sales competition and gross revenue of the clothes washer industry. As California uses more water than any state and will continue rapid population growth, we support a residential clothes washer water efficiency standard of 8.5 effective January 1, 2007 followed by a 6.0 standard effective January 1, 2010 to conserve and manage supplies for a growing population. Implementation of these standards will create tremendous water and energy savings for the region while supporting legal obligations to reduce use of imported water deliveries. It is crucial that California carries out these water efficiency standards and responsibly reduces its dependence on overly tapped and energy-intensive regional and imported water supplies. Water efficiency standards for residential clothes washers will help California achieve this goal. We sincerely hope you will approve the Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers. It is critical to the state's economy and quality of life of populations that will make California their home for generations to come.

ruce Michael Banks to Fe Irrigation Disfri



## 0000270

# FOOTHILL MUNICIPAL WATER DISTRICT ALTADENA e La CANADA FLINTRIDGE ® La CRESCENTA

March 21, 2006

Samuel W. Badman Secretary of Energy United States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Re: Support for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers Dear Mr. Secretary: On behalf of Foothill Municipal Water District , we strongly urge you to approve the Petition to Exempt from Preemption California 's Water Efficiency Standards for Residential Clothes Washers. California's water use is intricately linked to high energy costs and consumption. As the nation's largest water user with a vast water transportation infrastructure, California's water systems are uniquely energy-intensive due to pumping requirements to deliver volumes of water tong distances, across mountain ranges and over high elevations. The State Water Project, the nation's largest state-built water conveyance system of reservoirs, lakes, power plants, pump stations, canals, tunnels and a 444 mile-long aqueduct, is the largest single user of electricity in the state. The amount of energy required to support the state's water delivery system and energy requirements associated with treating, pumping and delivering water from water supply sources to population centers is of increasing concern throughout the state. It is clear that more efficient water use will substantially reduce energy costs and use. Due to the state's unique water and energy circumstances, California must pursue highly efficient and cost-effective energy and water conservation strategies and solutions. In 2002, the California State Legislature declared that "a significant portion of urban water demand in the state is for residential clothes washers" and that "water conservation is a proven tool that will make the most effective use of the state's limited supply, and will conserve energy." As a result of these declarations, the California Energy Commission adopted water efficiency standards for residential clothes washers to address the unique and compelling interests and needs of California. Implementation of state water efficiency standards will result in significant reduction in use and cost to pump, treat and provide reliable state water supplies while also reducing energy consumption and costs required to maintain and operate water delivery systems and wastewater treatment facilities, The amount of energy that will be conserved as a result of water efficiency standards will be significant. A fully implemented 8.5 water factor standard will save as much energy as the annual usage for approximately 50,000 California homes, and the 6.0 water factor will save the equivalent annual energy use of approximately 85,000 California homes. Along with increased consumer energy and water cost savings, these water efficiency standards would not burden the clothes washer industry. Instead, these standards would positively impact the manufacturing, marketing, distribution, sale and servicing of these high efficiency washers. Today, most appliance manufacturers, large and small, already produce these types of high efficiency washers and comply with proposed standards. While 30 percent of California's sale of

4536 Hampton Road • P.O. BoX 686 • La Canada Flintridge, CA 91012-0686 (818) 790-4036 FAX(818)790-9418 

## 00002 ^1washers already comply with the 8.5 standard, 20 percent of sales already comply with the 6.0 standard. Various rebate incentive and educational programs throughout the state are also in place to support and increase the sale of these washers and currently account for 39 percent of the market. However, if provided this preemptive waiver, California can achieve a 100 percent market share and increase sales competition and gross revenue of the clothes washer industry. As California uses more water than any state and will continue rapid population growth, we support a residential clothes washer water efficiency standard of 8.5 effective January 1, 2007 followed by a 6.0 standard effective January 1, 2010 to conserve and manage supplies for a growing population. Implementation of these standards will create tremendous water and energy savings for the region while supporting legal obligations to reduce use of imported water deliveries. It is crucial that California carry out these water efficiency standards and responsibly reduce its dependence on overly tapped and energy-intensive regional and imported water supplies. Water efficiency standards for residential clothes washers will help California achieve this goal. We sincerely hope you will approve the Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers. It is critical to the state's economy and quality of life of populations that will make California their home for generations to come. Sincerely,

William Pecsi General Manager Foothill Municipal water District
Docket number EE-RM -PET-100

O O() G 1'4'1 1'i 2

# MiscellaneousIf you need this publication in alternate form, contact the Public Affairs Office at I-800

-272-8869.



## 0000274Public Review Draft California Water Plan Update 2005 Volume 1-Strategic Plan



# California Water Plan Update 2005

About i raft
This Public Review Draft of California Water Plan Update 2005 is being released for a public comment period that ends June 30, 2005.
All volumes of the document are available in electronic form at www.waterplan.water.ca.gov. Volume 1 and Highlights (a brochure) are also available in print. The brochure, Highlights, holds a CD that contains all the volumes of this Public Review Draft. Please see contact information on next page to request additional copies or other volumes in print form.
The content of this document is sufficient for review purposes, but as you read this draft you will notice that the document is not in a finished form. A number of graphics are still under development. Such figures are noted in their title as being under development. Tables, figures, and boxes are for the most part presented at the end of each chapter. 

### Public hearings The Department of Water Resources welcomes your input through submission of written comments or participation in one of our public hearings. These hearings will be held at several locations throughout the state to summarize the key figures and content of Update 2005, answer questions, and receive comments. Below is a tentative list of community locations. Check out the water plan Web site at http://www.waterplan.water.ca %,. for current details on public hearings, or see next page for contact information.
(Tentative) Locations Bakersfield Redding Eureka Sacramento Los Angeles San Diego Oakland San Luis Obispo Palm Desert Tracy

Deadline for receiving comments on all volumes of this public review draft is: June 30, 2005



## 00002 75California Water Plan Update 2005 Volume 1-Strategic Plan Public Review Draft



### Who to contact
If you need this publication in alternate form, contact the Public Affairs Office at 1-800-272-8869.
For address, date, and time of each hearing, contact: Virginia Sajac Water Plan Administrative Support California Department of Water Resources (916) 653-7101 e-mail: vsaj c(a water.ca.gov Please send comments to: Paul Dabbs Statewide Planning Branch California Department of Water Resources P.O. Box 942836 Sacramento, CA 94236-0001 e-mail: pddabbsca water.ca.gov fax: (916) 651-9289 phone: (916) 653-5666

Or see Web site: http://www.waterplan.water.ca.fov!



## 000027 6State of California The Resources Agency Department of Water Resources



# A Framework for Action

California Water Plan Update Bulletin 160-05



# REVIEV4, D"RAF"T
April 2005

Arnold Schwarzenegger Mike Chrisman Lester A. Snow

Governor Secretary for Resources Director State of California The Resources Agency Department of Water Resources



## 00002 77California Water Plan Update 2005 Volume 1-Strategic Plan Public Review Draft



# UVO027Public Review Draft California Water Plan Update 2005 Volume 1-Strategic Plan

STATE OF CALIFORNIA Arnold Schwarzenegger, Governor 

### THE RESOURCES AGENCY Mike Chrisman , Secretary for Resources DEPARTMENT OF WATER RESOURCES Lester A. Snow , Director P. Joseph Grindstaff Chief Deputy Director
Brian E

. White Nancy J. Saracino Susan Sims-Teixeira Assistant Director Legislative Affairs Chief Counsel Assistant Director Public Affairs
Peter S

. Garris Stephen Verigin Deputy Director Deputy Director
Vernon T

. Glover Gerald E. Johns Deputy Director Deputy Director Division of Planning and Local Assistance

Mark Cowin, Chief Prepared under the direction of Kamyar Guivetchi , Program Manager of Statewide Water Planning, and the following management team Paula Landis San Joaquin District Mark Meeks Resource Restoration and Project Support Stephen Roberts Surface Storage Investigations Dwight Russell Northern District Mark Stuart Southern District Karl Winkler Central District John Woodling Conjunctive Water Management

Prepared under the supervision of Paul Dabbs , Project Manager,

and the following work team leads X. Tito Cervantes Water Supply and Balance Paul Dabbs Regional Reports Richard Juricich Data and Analytical Tools Jennifer Kofoid Information Technology Brenda Main Publications Paul Massera Resource Management Strategies

Scott Matyac Agricultural and Urban Water Use

Michael Perrone Environmental Water Use

Virginia Sajac Administrative and Logistical Support

Public process facilitated under DWR contract by Center for Collaborative Policy , California State University, Sacramento

V 

## 00 002 7 9California Water Plan Update 2005 Volume 1- Strategic Plan

Project Team Members by Work Team Public Review Draft

Administrative and Logistical Support

Alan Arroyo Tracey Lindberg Edna Smith Karen Buckner Will Murray Charlene Tallman Diane Buffenbarger Pat Separovich Nancy Van Buren Janiene Friend

Agricultural and Urban Water Use

Alan Aguilar Steve Ewert Morteza Orang Manucher Alemi Farhad Farnam Pat Parsons Luis Avila Robert Fastenau Marsha Prillwitz Kevin Bennett Sergio Fiero Neil Rambo G.I. Bergquist Marla Hambright Jim Rich David Bilyeu Tom Hawkins Mark Rivera Karen Brown Scott Hayes Jessica Salinas Emil Caizascia Todd Hillaire David Scruggs Mary Ceaser David Inouye Gholam H. Shakouri X. Tito Cervantes Kelly Lawler Jeff Smith Rich Cocke Richard Le Steve Turner Barbara Cross Lorraine Marsh Monique Wilber Baryohay Davidoff Cynthia Moffett Jean Woods Jamie Dubay Ed Morris

Data and Analytical Tools Sushil Arora Ray Hoagland Mohammad Rayej X. Tito Cervantes Richard Le David Scruggs Sina Darabzand Paul Massera Sanjaya Seneviratne Farhad Farnam Scott Matyac Greg Smith Michael Floyd Chris Montoya David Sumi Marla Hambright Michael McGinnis Evelyn Tipton Tom Hawkins Morteza Orang Todd Hillaire Doug Osugi
Environmental Water Use Alan Aguilar Kelly Lawler Richard Neal Manucher Alemi Ginger Lu Kent Nelson X. Tito Cervantes Jim Martin Mohammad Rayej Rich Cocke Michael McGinnis Jean Woods Todd Hillaire Chris Montoya Bob Zettlemoyer Jennifer Kofoid Ed Morris Information Technology Jan Fetler Thien Nguyen Greg Smith Scott Hayes Brian Niski David Sumi Jackson Lee Virginia Sajac Phillip Vo Mike Mullen Eric Senter Monique Wilber

vi 

## 0000230Public Review Draft California Water Plan Update 2005 Volume 9-Strategic Plan

Publications Nikki Blomquist John Carter Teresa Chaney Patricia Cornelius Volume Editors Volume 1 Marilee Talley Volume 2 Loren Bottorff

Paul Massera Mike Durant Gretchen Goettl Mike Miller Carole Rains
Volume 3 Paul Dabbs Volume 4 John Andrew Volume 5 Jennifer Kofoid Rick Soehren Phyllis Yates Joanne Pierce

Cover and Design Chris Sanchez Regional Reports Alan Aguilar David Inouye Eugene Pixley John Andrew Vern T. Knoop Tim Ross G.I. Bergquist Jennifer Kofoid Diane Sanchez Loren Bottorff Ginger Lu David Scruggs X. Tito Cervantes Paul Massera David Sumi Robert Fastenau Michael McGinnis Garret Tam Sing Matt Filice Chris Montoya Evelyn Tipton Charles Ferchaud Ed Morris Jennifer Wong Todd Hillaire Matt Nolberg Jean Woods Resource Management Strategies

Man ucher Alemi Ray Hoagland Marsha Prillwitz John Andrew Rich Juricich, Asst Lead Dean Reynolds Jeremy M. Arrich Fawzi Karajeh Maurice Roos Emil Calzascia Charles F. Keene Brian E. Smith X. Tito Cervantes Luana Kiger Rick Soehren Steve Cowdin Vern T. Knoop David Sumi, Asst Lead Baryohay Davidoff Stefan Lorenzato David Todd Michael Floyd Matt Nolberg Jim Wieking Ted Frink Douglas Osugi Iris Yamagata Carl Hauge Elizabeth Patterson Todd Hillaire Michael Perrone

Water Supply and Balance Alan Aguilar Ginger Lu Jessica Salinas Emil Calzascia Michael McGinnis David Scruggs Jamie Dubay Chris Montoya Rob Swartz Charles Ferchaud Ed Morris Evelyn Tipton Matt Filice Richard Neal Ken Turner Todd Hillaire Matt Nolberg Iris Yamagata David Inouye Bob Pierotti Bob Zettlemoyer Vern T. Knoop Maurice Roos Kelly Lawler Tim Ross Other Support Staff Linda Ackley Roger Canfield Barbara Cross Olivia Guebara Devinder Sandhu Peggy Bernardy Office of Chief Counsel Public Affairs Environmental Justice and Tribal Coordination Legislative Affairs Office Office of Chief Counsel Office of Chief Counsel

viiCalifornia Water Plan Update 2005 Volume 1-Strategic Plan Public Review Draft

Facilitation Team ( Center for Collaborative Policy , California State University, Sacramento) Lisa Beutler, Lead
Gina Bartlett David Booher Susan Carpenter Dave Ceppos Scott Ferris Rayma Forrest Sarah Goldberg Amy Hall Sharon Huntsman Anya Lawler Julia Lee Geraldine Nicholson Teresa Pal Susan Sherry David Sumi Judith Talbot Gregory Weber

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# 00002 82Public Review Draft California Water Plan Update 2005 Volume 1-Strategic Plan


## Members of the Public Advisory Committee
Margit Aramburu

- Delta Protection Commission Alternate: Lori Clanurro Mary Bannister-Pajaro Valley Water Management Agency Kirk Brewer-CA Water Association Merita Callaway-CA State Assoc. of Counties Scott Cantrell-CA Dept of Fish and Game Grace Chan-Metropolitan Water District of Southern California Alternates: Don Bentley, David Fullerton Jim Chatigny-Mountain Counties Water Resources Association Alternate: Merv de Haas Marci Coglianese-League of California Cities Alternate: Dan Secord, M.D. Bill Cunningham-Natural Resources Conservation Service, U.S. Dept of Agriculture Alternate: Walter Sykes Grant Davis-Bay Institute of San Francisco Martha Davis-inland Empire Utilities Agency. Mary Ann Dickinson-California Urban Water Conservation Council Alternate: Katie Shulte-Joung Nick Di Croce-California Trout Anisa Divine-Imperial Irrigation District William DuBois-CA Farm Bureau Federation Alternates: Michele Dias, Rebecca Sheehan Howard Franklin-Monterey County Water Resources Agency Lloyd Fryer-Kern County Water Agency Bill Gaines-California Waterfowl Association Alternate: Mark Hennelly Fran Garland-Contra Costa Water District Peter Gleick-Pacific Institute for Studies in Development, Environment, and Security Alternate: Dana Haasz Zeke Grader-Pacific Coast Federation of Fishermen's Associations Brent Graham Tulare Lake Basin Water Storage District David Guy-Northern California Water Association Alternate: Todd Manley Martha Guzman-United Farm Workers of America Diana Hershey-Robinson Rancheria Band of Porno Indians Alex Hildebrand-South Delta Water Agency Mike Hoover-U.S. Fish and Wildlife Service Alternate: Mark Littlefield Bill Jacoby-WateReuse Association Craig Jones-State Water Contractors, Inc. Alternate: Mary Lou Cotton Rachel Joseph-Lone Pine Paiute-Shoshone Tribe Alternate: Teri Cawelti-Owens Valley Indian

Water Commission Kevin Kauffman-Stockton East Water District Alternate: Anthony Barkett Steve LaMar-CA Building Industry Assoc. Alternate: Mike Webb Joseph Lima-Modesto Irrigation District Jay Lund-University of California, Davis Steve Macaulay-California Urban Water Agencies Alternate: Elaine Archibald Jennifer Martin-The Nature Conservancy Alternate: Peter Yoles Benjamin Magante . Sr.-San Luis Rey Indian Water Authority William Miller (B.J) -Consulting Engineer John Mills-Regional Council of Rural Counties Clifford Moriyama-California Business Properties Association Alternate: Steve Lamar Valerie Nera-California Chamber of Commerce James Noyes-Southern California Water Committee, Inc. Alternate: Alan Gribnau Enid Perez-Del Rey Community Services Lloyd Peterson-U.S. Bureau of Reclamation Alternate: Al Candlish Cathy Pieroni-City of San Diego Water Department Nancy Pitigliano-Tulare County Farm Bureau Alternate: Cheryl Lehn Betsy Reifsnider-Friends of the River Terry Roberts-Governor's Office of Planning and Research Larry Rohlfes-CA Landscape Contractors Assoc. Spreck Rosekrans-Environmental Defense Alternate: Ann Hayden Jennifer Ruffolo-CA Research Bureau Steve Shaffer-CA Dept of Food and Ag.

ixCalifornia Water Plan Update 2005 Volume 1-Strategic Plan Public Review Draft

Polly Osborne Smith-League of Women Voters of California Jim Snow-Westlands Water District Alternate: Brian Hauss Frances Spivy-Weber-Mono Lake Committee John Sullivan-League of Women Voters Walter Swain-U.S. Geological Survey Greg Thomas-Natural Heritage Institute Alternate: Rich Walkling Michael Wade-CA Farm Water Coalition Michael Warburton-The Ecology Center of Berkeley Tom Ward-CA Dept Parks & Recreation Alternate: Eric Natti Arnold Whitridge-Trinity County Robert Wilkinson-University of CA, Santa Barbara Kourt Williams-Executive Partnership for Environmental Resource Training Carolyn Yale-U.S. Environmental Protection Agency Gary Yamamoto-CA Dept of Health Services Tom Zuckerman--Central Delta Water Agency
Past members of the Public Advisory Committee Dirk Brazil-CA Department of Fish and Game, 2001 Burt Bundy-California Farm Bureau Federation, Los Molinos, 2001-2002 Jim Bybee-National Marine Fisheries Service, Santa Rosa, 2001 Dave Cox-CA Department of Parks & Recreation, 2002-2003 Ed Craddock-Department of Water and Resource Conservation, Butte County, 2002 Stan Dixon-County of Humboldt, Eureka, 2001 John Eckhardt-Imperial Irrigation District, 2001 Torri Estrada-Organ Habitat Program, San Francisco, 2001 Paul Gagliardo-City of San Diego, 2001-2002 Marcus Garret-Santa Rosa Band of Mission Indians, 2001 Brian Grattidge-Governor's Office of Planning and Research, 2003 Elston Grubaugh-Imperial Irrigation District, 2002 Wes Lujan-Regional Council of Rural Counties, Sacramento, 2001 Peter MacLaggan-WateReuse Association, San Diego, 2001 Ken Norton-Hoopa Valley Tribe, 2001-2002 Dennis O'Connor-California Research Bureau, 2001-2002 Walter Pettit-California Urban Water Agencies, 2001-2002 Dale Pierce-U.S. Fish and Wildlife Service, Sacramento, 2001 Robert Quitiquit-Robinson Rancheria, 2002-2003 Steve Shaffer-CA Department of Food and Agriculture, 2001-2003 Angela Sherry-Environmental Defense, Oakland, 2001-2002 Katie Shulte Joung-Governor's Office of Planning and Research, 2001-2002 Van Tenney-Glenn-Colusa Irrigation District, Willows, 2001 Brian White-CA Building Industry Assoc. Chris Williams-Mountain Counties Water Resources 'Association, 2001-2002 Lois Wolk-California State Association of Counties, 2001-2002 Joseph Young-California Water Association, 2002

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## ®®00284Public Review Draft California Water Plan Update 2005 Volume 1-Strategic Plan 

# Acknowledgment In 2001, the Department of Water Resources sought to make the California Water Plan more useful to its traditional users and of value to a broader audience. The undertaking required an open, fair, and transparent process that embraced ideas from all California's communities: State and federal, regional and local agencies, agriculture and municipalities, industry and business, environmental groups, tribal interests and other traditionally underrepresented groups, and the general public. Names of the many participants appear on the lists before and after this acknowledgement. DWR regrets if any name has been inadvertently left off. This water plan update was truly a team accomplishment.
The success of this water plan update is owed to the countless individuals who generously shared their talents and expertise during this long and sometimes arduous process. Because of the many years that it took to develop this water plan update, many dedicated individuals, through retirement or other circumstances, could not stay involved until completion of the project-including former chief deputy director Steve Macaulay, former deputy directors Jonas Minton and Lucinda Chipponeri, and former division chief Naser Bateni. The contributions of all these participants have been significant to the final document.
Through contracts with DWR, several organizations and individuals played important roles in developing this water plan update. Center for Collaborative Policy at California State University Sacramento helped bring together California's water communities to shape the first water plan update of the 2151 century. Other contractors who played an integral role are acknowledged here for their special contributions: Loren Bottorff worked closely with DWR staff over several years and played a key role in preparing several of these volumes; Ken Kirby provided important insight and written content for Chapter 4 Preparing for an Uncertain Future: Susan Tatayon and David Kracman helped write Chapter 2 A Framework for Action.

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## 0285California Water Plan Update 2005 Volume 1-Strategic Plan Public Review Draft

Administrative Support
Dave Bolland, ACWA Mike Henry, California Farm Nadine Scott, California Water Coalition Association of Resource David Briggs Contra Costa

, Conservation Districts Water District Lisa Holm, ASCE, Bay Area Chapter Jill Sherman EPA Region IX George Chiu Vice-President ,

, , Tribe San Francisco Section Yvonne Hunter League of ASCE California Cities Lou Smallwood, San Joaquin Valley Water Coalition Kerry Cowlishaw, Texas Water David Nesmith, Environmental Development Board Water Caucus Barbara Solarez , Modesto Irrigation District Rick Harter, Los Angeles and Lisa Ring, Southern California San Gagriel Rivers Water Company Tami Stuart, Agua Caliente Band Watershed Council of Cahuilla Indians CALFED Regional Coordination California Bay-Delta Authority Cindy Darling Kathy Caldwell Vickie Newlin Schlumberger Water Services Susan Tatayon

Ron Ott Commentators Larry Adams, Santa Clara Valley Robert Feraru, Public Charles H. Lawrance, Public Water District Amy Fowler, Santa Clara Valley C. Mel Lytle, San Joaquin Anthony W. Araiza, West San Water District County Flood Control & Bernadino County Water Water Conservation District District Dennis G. Fox, Soil and Water Conservation Society; Einar Maisch, Placer County Betty Berteaux, Public California Native Grass Water Agency Association Stephen Bilson, ReWater Mindy McIntyre, Planning and Systems, Inc. Donna Garcia, US Bureau of Conservation League Reclamation Gary Bobker, The Bay Institute Harry Moore, American of San Francisco Larry Gardner, City of San Diego Construction Inspectors Association Steven Book, California David Groves, RAND Department of Health Corporation Barry Nelson, National Services Resources Defense Council Edward Hall, Extended Review Marcia Brockbank, San Forum member Michael Nurre, Public Francisco Estuary Project Ken Harris, State Water Dennis O'Connor, Senate Tina Cannon Roberts, California Resources Control Board Committee on Agriculture Department of Fish and and Water Resources Games Cliff Hurley, Public Mark Chainey, Sierra Foothills Audubon Society Henry Ingram, Sacramento Metropolitan Water Authority Felice Pace, Klamath Forest Alliance Ed Pandolfino, Public Carolyn Chainey-Davis, Jacqueline Jacobberger League Wa ne Pierson State Water California Native Plant , y , Society of Women voters of Resources Control Board California Nancy Harris Dalwin Public John Pulver, San Joaquin

, Tom Keegan, Rancheria Brand County Flood Control & David G. Emery Public of Pomo Indians Water Conservation District Barbara Evoy, State Water Cynthia Koehler, Save the Bay Stuart T. Pyle, Public Resources Control Board

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# 6Public Review Draft California Water Plan Update 2005 Volume 9-Strategic Plan

Margie Lopez Read, State Water Angela Sherry, Environmental Arthur Unger, Sierra Club Resources Control Board Defense Katherine Wang, Public Chuck Rose Sacramento North Stanley E. Sprague Municipal

, Area Groundwater , Water District of Orange Don Zyistra, Kennedy/Jenks Management Authority County Consultants Jack Schoop, Public Scott J. Steward , ConservaSeed

Guest Speakers Sushil Arora, Department of Water Resources Charles Burt, California Polytechnic Art Jensen, Bay Area Water Users Association Jerry Johns, Department of Water Resources Maury Roos, Department of Water Resources Dwight Russell, Department of Water Resources Virginia Cahill, State Department Ken Kirby, Private Consultant Brian Smith, Department of of Justice Water Resources John Ladd, State Water Dan Cayan, Scripps Institute Resources Control Board Jan Stevens, California Department of Justice Daniel Cozad, Santa Ana Anya Lawler, Governor's Office Watershed Project of Planning and Research Dan Sumner, University of California Agricultural David Goldhamer University of Ron Linsky National Water

, , Issues Center California, Davis Research Institute David Groves, RAND Corporation Stefan Lorenzato, Department of Water Resources Rob Swartz, Department of Water Resources Carl Hauge, Department of Water Resources Bill Mullican, Texas Water Development Board Greg Thomas, Natural Heritage Institute Tom Ward State Parks Richard Howitt, University of Lowell Ploss, San Joaquin River , California Agricultural Group Authority Leo Winternitz, Water Forum Issues Center Marsha Prillwitz, Department of Gerry Zimmerman, Colorado Bill Jacoby, San Diego County Water Resources River Board Water Authority Steve Roberts, Department of Water Resources
Logistical Support
Clarion Hotel Diana Gomes Terry Homrig Vishwa Nand Double Tree Hotel Steve Tatro Kinko's Jason Ewing Radisson Hotel Sacramento Laura Baer Sterling Hotel Angie Chavez Robert Cortvriendt Mindy Fernandez Lynelle Hansen Karen Sprague

OOO2 bCalifornia Water Plan Update 2005 Volume 1

- Strategic Plan

Subject Matter Experts (by organization) Public Review Draft

Active Curiosity Ken Kirby Susan Tatayon California Water and Environmental Modeling Forum Rich Satkowski City of Santa Monica Governor's Office of Planning and Research Brian Grattidge Anya Lawler Terry Roberts Kern County Water Agency Rick Iger Kessler and Associates, LLC State Water Resources Control Board Jarma Bennett Rik L. Rasmussen Margie Lopez Read Nancy Richard Laura Sharpe Ling Tseng Neal Shapiro John S. Kessler Tree People Department of Food and League to Save Sierra Lakes Andy Lipkis Agriculture Brad Pearson David O'Donnell Steve Schaffer California Department of Justice Los Angeles & San Gabriel University of California

, Rivers Watershed Council Agricultural Issues Center Attorney General's Office Suzanne Dallman Heinrich Brunke Virginia Cahill Department of Land, Air and Natural Heritage Institute Richard Howitt Water Resources, UC Davis David Purkey Daniel Sumner Theodore C. Hsiao Greg Thomas University of California Davis, IAS-CSIC Liukang Xu Pacific Institute for Studies in Sara Sarreshteh Development, Environment, David Goldhamer and Security Department of Parks and University of California, Berkeley Peter H Gleick Recreation . Jeff Deason Michael Kiparsky Eric Natti Jessica Fast Alexandra Stehl Public Policy Institute of California Lisa Schroeer Tom Ward Brian Turner Ellen Hanak Dave Cox, retired Renske van Staveren RAND Corporation Environmental Defense Ann Hayden Spreck Rosekrans Fresno Metropolitan Flood Control District Daniel Rourke David Groves Schlumberger Water Services David Kracman Scripps Institute Dan Cayan University of California, Davis Shu Geng Richard Snyder University of Cordoba, Spain Elias Fereres

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## 00 0028 -78Public Review Draft California Water Plan Update 2005 Volume 1-Strategic Plan 

# Acronyms and Abbreviations

CaIEPA CEQA CVPIA CWEMF DFG DOF DWR EGPR EISIEIR EWA GATS IOU IPCC IRWM ISI LORP NEPA NOAA OPR PIER QSA ROD SCADA SJRMP SWRCB TROA California Environmental Protection Agency California Environmental Quality Act Central Valley Project Improvement Act California Water and Environmental Modeling Forum California Department of Fish and Game California Department of Finance California Department of Water Resources Environmental Goals and Policy Report Environmental impact stateinent/environmental impact report Environmental Water Account General Agreement on Trade Services Investor owned utility Intergovernmental Panel on Climate Change Integrated regional water management Integrated Storage Investigations Program Lower Owens River Project National Environmental Policy Act National Marine Fisheries Service (Governor's) Office of Planning and Research Public Interest Energy Research Program Quantification Settlement Agreement Record of Decision Supervisory Control and Data Acquisition San Joaquin River Management Program State Water Resources Control Board Truckee River Operating Agreement TRPA Tahoe Regional Planning Agency UFP Unified Federal Policy UWMP Urban Water Management Plan WQCP Water Quality Control Plan WTO World Trade Organization

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## 0000289California Water Plan Update 2005 Volume 1-Strategic Plan Public Review Draft

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## JloPublic Review Draft California Water Plan Update 2005 Volume 1-Strategic Plan 

## Contents Highlights California Water Plan Update 2005 Highlights (a brochure)
Volume 1

- Strategic Plana Chapter I Introduction Chapter 2 A Framework for Action Chapter 3 California Water Today Chapter 4 Preparing for an Uncertain Future Chapter 5 Implementation Plan References

Volume 2 - Resource Management Strategies Chapter 1 Chapter 2 Chapter 3 Chapter 4 Chapter 5 Chapter 6 Chapter 7 Chapter 8 Chapter 9 Chapter 10 Chapter 11 Chapter 12 Chapter 13 Chapter 14 Chapter 15 Chapter 16 Chapter 17 Chapter 18 Chapter 19 Chapter 20 Chapter 21 Chapter 22 Chapter 23 Chapter 24 Chapter 25 Chapter 26 Introduction

Agricultural Land Stewardship Agricultural Water Use Efficiency Conjunctive Management and Groundwater Storage Conveyance Desalination Drinking Water Treatment and Distribution Economic Incentives (Loans, Grants, and Water Pricing) Ecosystem Restoration Floodplain Management Groundwater Remediation/Aquifer Remediation Matching Water Quality to Use Pollution Prevention Precipitation Enhancement Recharge Area Protection Recycled Municipal Water Surface Storage-CALFED Surface Storage-Regional/Local System Reoperation Urban Land Use Management Urban Runoff Management Urban Water Use Efficiency Water Transfers Water-dependent Recreation Watershed Management Other Strategies

" A more complete contents list precedes each chapter in Volume 1.

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## 00 00291.California Water Plan Update 2005 Volume 1-Strategic Plan Public Review Draft

Volume 3 - Regional Reports Chapter 1 State Summary Chapter 2 North Coast Hydrologic Region Chapter 3 San Francisco Bay Hydrologic Region Chapter 4 Central Coast Hydrologic Region Chapter 5 South Coast Hydrologic Region Chapter 6 Sacramento River Hydrologic Region Chapter 7 San Joaquin River Hydrologic Region Chapter 8 Tulare Lake Hydrologic Region Chapter 9 North Lahontan Hydrologic Region Chapter 10 South Lahontan Hydrologic Region Chapter 11 Colorado River Hydrologic Region Chapter 12 Sacramento-San Joaquin Delta Chapter 13 Mountain Counties
Volume 4 - Reference Guide Background A California Water Chronology (by the Water Education Foundation) A Look Back at Past California Water Plans • Bay Delta Standards Contained in D- 1641 • Selected Task Force and Advisory Panels • Selected Water Prices in California • Water Allocation, Use and Regulation in California • What's So Special About Special Districts? A Citizen's Guide to Special Districts in California (3rd Edition) (by Kimia Mizany and April Manatt, CA Senate Local Government Committee) Crop Water Use • Central Valley Crop Classification Processing Using Remote Sensing and GIS Technologies (by Jeff Milliken, Marlette Shin, David Hansen, Charles Johnson, Michael Sebhat, Joel Zander - USBR Mid Pacific Region) • CUP (Consumptive Use Program) Model (by Morteza Orang, Richard Snyder, Scott Matyac, DWR and UC Davis) • Evaporation Research -- A Review and Interpretation (by C.M. Burt, A.J. Mutziger, R.G. Allen, and T.A. Howell • Evapotranspiration and Relative Contribution by the Soil and the Plant (by Theodore Hsiao and Liukang Xu, UC Davis) • Evapotranspiration from a Satellite-based Surface Energy Balance for the Snake Plain Aquifer in Idaho (by Richard G. Allen. Anthony Morse, Masahiro Tasumi, Ricardo Trezza, Wim Bastiaanssen, James L. Wright, and William Kramber)

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## 0000292Public Review Draft California Water Plan Update 2005 Volume 1-Strategic Plan

(Volume 4 - Reference Guide contents continued) ® Limits to the Productivity of Water in Crop Production (by Andrew Keller and David Seckler) Model for Estimating Evaporation and Transpiration from Row Crops (by Francesca Ventura, Ben A. Faber, Khaled M. Bali, Richard L. Snyder, Donatella Spano, Pierpaolo Duce, and Kurt F. Schulbach) Originally published in Journal of Irrigation and Drainage Engineering, American Society of'Civil Engineers. Nov/Dec 2001. Obtained from http://www.pubs.asce.org/ ® The Promise of Regulated Deficit Irrigation in California's Orchards and Vineyards (by David Goldhamer and Elias Fereres, UC Davis, IAS-CSIC and University of Cordoba, Spain) SIMETAW (Simulation of Evapotranspiration of Applied Water) (by Richard Snider, Morteza Orang, Shu Geng, Scott Matyac, and Sara Sarreshteh, UC Davis and DWR) Data and Analytical Tools ® Future Quantitative Analysis for California Water Planning (by Ken Kirby, SKS Consultants) ® Strategic Analysis Framework to Guide Future Development of Analytical Tools for Managing Water in California. Draft Summary Report .(by California Water and Environment Modeling Forum) ® Survey of Irrigation Methods in California in 2001 (by Morteza Orang, Richard Snider, and Scott Matyac, DWR and UC Davis) ® Quantified Scenarios of 2030 California Water Demand (by David Groves, Pardee RAND Graduate School, and Scott Matyac and Tom Hawkins, DWR)
Environment ® Applying the Public Trust Doctrine to River Protection (By Jan S. Stevens) ® Considering Water Use Efficiency for the Environmental Sector (by Jeff Deason, Jessica Fast, Lisa Scroeer, Brian Turner and Renske van Staveren, UC Berkeley) Recommendations Regarding Scenarios and Application of Environmental Water "Demands" in the State Water Plan Update & Quantification of Unmet Environmental Objectives in State Water Plan 2003 Using Actual Flow Data for 1998, 2000, and 2001 (by Environmental Defense)
Environmental Justice ® Environmental Justice in California Government (by Governor's Office of Planning and Research) a General Plan Guidelines, Chapter 2: Sustainable Development and Environmental Justice (by Governor's Office of Planning and Research)

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(Volume 4 - Reference Guide contents continued) Global Climate Change • Climate Change and California Water Resources: A Survey and Summary of the Literature (by Michael Kiparsky and Peter H. Gleick, Pacific Institute for Studies in Development, Environment, and Security) • Accounting For Climate Change (by Maurice Roos, DWR) Hydrology • California River Indices • Frequency of a 100 Year Flood • Major Floods Since 1950 • Severity of Extreme Droughts in Sacramento and San Joaquin Valley
Infrastructure • California's Major Water Projects • California Reservoirs • CALFED Bay-Delta Surface Storage Investigations Progress Report, April 2005. (by DWR, USBR, and California Bay-Delta Authority) • Hydropower Projects Relicensing Landscape Water Use • Urban Landscape Evapotranspiration (by Richard L. Snyder, University of California, Atmospheric Science, Davis, California, and Simon Eching, DWR) • Vegetative Assessment in an Urban Environment (by Alan Walters, Agricast) Legislation • Recent Water Legislation (by DWR Legislative Affairs Office staff) • Water Bonds • Water Plan Legislation • Work Plan for Meeting Legal Requirements for the California Water Plan Litigation • Joint Statement on the Monterey Amendments Litigation (by DWR, Central Coast Water Authority, State Water Contractors, Planning and Conservation League, Plumas County Flood Control and Water Conservation District, and the Citizens' Planning Association of Santa Barbara County) • Summary of Significant Litigation 1998-2005 (by DWR, Office of Chief Counsel)



## xx 0000294Public Review Draft California Water Plan Update 2005 Volume 1-Strategic Plan

(Volume 4 - Reference Guide contents continued) Planning • Addressing California's Uncertain Water Future by Coordinating Long-Term Land Use and Water Planning: Is a Water Element in the General Plan the Next Step? (by Ryan Waterman). Originally published in Ecology Law Quarterly, Vol 31:1 p.1 17, (c) 2004 by the Regents of the University of California. • Customer & Stake Holders Survey for CWP Update 2003 • Financing Strategies and Guidelines for Funding Water Resource Projects (by David Kracman, Schlumberger Water Services) • Financing Strategies and Guidelines for Funding Water Resource Projects (by David Kracman, Schlumberger Water Services) • Future Food Production and Consumption in California Under Alternative Scenarios (by Henrich Brunke, Richard Howitt and Daniel Sumner, University of California Agricultural Issues Center) • Future Scenarios Presented in Water Plan Update 2005 • Involving Stakeholders in Irrigation and Drainage District Decisions: Who, What, When, Where, Why, How (by Lisa Beutler, Center for Collaborative Policy) • Planning For Extreme and Prolonged Drought Conditions • Planning Framework for Water Plan Update • Strategic Planning Guidelines

Tribal Consultation • Interim Tribal Consultation Guidelines, Supplement to General Plan Guidelines (by Governor's Office of Planning and Research)
Water Quality • California Nonpoint Source Encyclopedia (prepared for State Water Resources Control Board by Tetra Tech, Inc.) htW://www.swrcb.ca.,^zov/nps/encyclopedia.htm • Californians Without Safe Water (by Monique Wilber) • California Water Quality in 2004 (written and edited by John Andrew, DWR) Glossary
References

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# Chapter 1 Introduction
Contents Chapter 1 Introduction ...... ................................... ...................................................................................... 1-1 Changing the Water Plan ........................................................................................................................1-1 New Process ...........................................................................................................................................1-2 New Features. ............................................................................................ ............................................ 1-3 Strategic Planning Document ........... ..................................................................................................1-3 Water Portfolios .............................. ...............................................................................................1-3 Regional Reports ................................................................................................................................1-4 Future Scenarios .................................................................................... .......................................1-4 Resource Management Strategies ....................................................................................................... 1-4 Phased Work Plan and Schedule ............................................................................................................1-5 Organization of California Water Plan Update 2005 .............................................................................1-5 Water Plan Update 2005 Highlights ..................................................................................................1-6 Volume 1 Strategic Plan .....................................................................................................................1-6 Volume 2 Resource Management Strategies ......................................................................................1-6 Volume 3 Regional Reports ................................................................................................................1-7 Volume 4 Reference Guide (The Encyclopedia Water Plan) .............................................................1-7 Volume 5 Technical Guide (Online Documentation) .........................................................................1-7


### Boxes (where cited in text) Box 1-1 Updates of the California Water Plan (Bulletin 160 series ) ........................................................1-1 Box 1-2 Legal Requirements for California Water Plan ...........................................................................1-2 Box 1-3 Strategic Plan: Components as Used for the Water Plan ............................................................1-3 Box 1-4 Water Management Objectives ...................................................................................................1-4 Box 1-5 Analytical Changes .. ...................................................................................................................1-4

Boxes' Box 1-1 Updates of the California Water Plan (Bulletin 160 series) ........................................................1-8 Box 1-2 Legal Requirements for California Water Plan .........................................................................1-10 Box 1-3 Strategic Plan: Components as Used for the Water Plan ..........................................................1-12 Box 1-4 Water Management Objectives .................................................................................................1-13 Box 1-5 Analytical Changes ...................................................................................................................1-15

t Find boxes at end of this chapter. They are placed in order of appearance in text.

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# 0 00 0 2 96Public Review Draft California Water Plan Update 2005 Volume I - Strategic Plan Chapter 1 Introduction 

# Ch Introduction
About This Chapter Chapter 1 Introduction outlines the process under which California Water Plan Update 2005 was prepared and its new features, which will become the cornerstone of future updates. It also explains the organization of all five volumes of Update 2005 and its Highlights brochure. ® Changing the Water Plan • New Process • New Features ® Phased Work Plan and Schedule ® Organization of Water Plan Update 2005



## Changing the Water Plan
The California Water Plan and its updates have been important sources of information for water planners since 1957 (see Box 1-1 Updates of the California Water Plan). As a master plan, it guides the orderly and coordinated control, protection, conservation, development, management, and efficient use of the water resources of the state (Water Code, § 10005(a)). Periodically, the California Department of Water Resources (DWR) has updated the water plan with revised estimates of future water demands and the delivery capability of existing and planned facilities. The difference between those estimates of water demand and supply is sometimes called "the gap."

Box 1

- 1 Updates of the California Water Plan (Bulletin 160 series)

Over the past 40 years, California water management has changed significantly. State and federal projects have not expanded as originally expected; in fact, deliveries have been reduced in recognition of environmental needs. In response, regional water planning has begun to integrate multiple water and resource management activities to meet a wide range of local objectives. Water agencies, local governments, and the Legislature need a water plan that promotes and supports integrated regional water management and helps State government meet its responsibilities for improving statewide water management systems.
California Water Plan Update 2005 addresses our changing water management and better reflects the roles of the State and federal governments and the growing role of regional and local agencies in California water management. It goes beyond trying to forecast and quantify a simple "gap" between statewide supply and demand. It is a roadmap for meeting the state's water demands through the year 2030. Update 2005 charts a Framework for Action that will help us sustain our water resource use and manage our supplies to ensure that water is available where and when it is needed. Its new features include a strategic plan with vision, goals, recommendations and implementation plan, an analytical approach with extended information and tools, use of water portfolios, regional reports, future scenarios, and resource management strategies.

1-1California Water Plan Update 2005 Volume I - Strategic Plan Public Review Draft Chapter 1 Introduction

In preparing this update, DWR sought the participation of California's water communities, responded to new State laws, and developed a new framework to planning California's water future. The result of this new and expanded public process is a water plan that includes the very best ideas for meeting our water challenges.

Box 1 -2 Legal Requirements for California Water Plan

By statute the California Water Plan cannot mandate actions nor authorize spending for its recommendations. California Water Plan Update 2005 makes neither project-specific nor site-specific recommendations; therefore, it does not include environmental review and documentation as required by the California Environmental Quality Act. Consequently, policy-makers and lawmakers must take further action to adopt the recommendations in this water plan and develop funding methods to help in their implementation. This underscores the need to have broad public participation and support for the water plan in order to have its recommendations realized.



## New Process
This update recognizes the vital importance of working with key stakeholders to define issues, identify potential management responses, and evaluate planning steps. Since January 2001 DWR has worked with a 65-member advisory committee, a 350-member extended review forum, and 2,000 interested members of the public. The advisory committee is composed of representatives of agriculture, urban water districts, businesses, environmentalists, American Indians, environmental justice advocacy, cities, counties, federal and State agencies, the California Bay-Delta Authority, academia, and different regions of California.
DWR sought a broadly informed and consensus-seeking process. Using large group meetings held roughly every six weeks for three years, more frequent smaller work groups and workshops, and many public briefings. Advisory committee members provided the Department with substantial suggestions and recommendations on all aspects of this update.
As part of their membership obligations, advisory committee members periodically briefed their constituencies on key developments. Members relayed comments received during these briefings to DWR. The briefing process helped ensure two-way communication between members and their organizations. In addition, briefings formally expanded the dialogue beyond the advisory committee into a wider audience of potential users of California Water Plan Update 2005. Public outreach and involvement during the preparation of the plan are described in Volume 4 Reference Guide articles "Planning Framework for Water Plan Update" and "Customer and Stake Holders Survey."
The Internet provided another principal venue for advisory committee work. DWR used e-government technology to set up Web pages and electronic surveys, and used e-mail correspondence and teleconferencing whenever possible. DWR posted meeting agendas, materials, and highlights, including draft copies of the water plan update, for all to see. DWR also posted data, assumptions, and documentation on the public Web site for use by advisory committee members and other interested parties.

1-2 O OO29Public Review Draft California Water Plan Update 2005 Volume I - Strategic Plan Chapter 1 Introduction

To create a fair, open and transparent process, the California State University Sacramento, Center for Collaborative Policy provided impartial third party facilitation and mediation design, implementation, and refinement for the consensus-seeking process. The center ensured advisory committee members' interests, views, and opinions were thoughtfully considered and advisory committee activities were governed by its own operating guidelines.
This new process is one of the significant accomplishments of this water plan. The principles of a fair, open, and transparent process should serve as the cornerstone for future updates because they (1) considerably expand public involvement and access to the State's water planning process; (2) seek collaborative recommendations that are stronger, have greater longevity, and are more likely to be adopted by the Governor's Office, Legislature, State, federal and local agencies and governments, and resource managers; and (3) produce a strategic plan with a vision, mission, goals, recommendations, and implementation plan.



## New Features

Following are some significant accomplishments of California Water Plan Update 2005 that provide California's water leaders with useful tools and can serve as the cornerstone for future updates.

Strategic Planning Document The water plan has become a strategic planning document that describes the role of State government and the growing role of California's regions in managing the state's water resources. Considerable public involvement has brought strong recommendations to this strategic plan.

Box 1

-3 Strategic Plan: Components as Used for the Water Plan

Water Portfolios
State and regional water portfolios cover the entire hydrologic cycle and water quality conditions consisting of more than 80 categories of water use, supply, and management. Actual data are used for 3 recent but different water years- 1998 (wet); 2000 (average), and 2001 (driest since extended drought when preparing this update). Water portfolios include flow diagrams, flow diagram tables, water balances, water quality reports, and summary table and charts and identify data gaps. (See Volume 3 Regional Reports, Chapter 1 State Summary for more information about the water portfolio concept.)

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# 0 X00299 ItyCalifornia Water Plan Update 2005 Volume I - Strategic Plan Public Review Draft Chapter 1 Introduction

Regional Reports In compliance with SB 672 (Stats. 2001, ch. 320), a regional report has been prepared for each of the 10 hydrologic regions, the Sacramento-San Joaquin River Delta, and the Mountain Counties overlay area. Each report includes the region's major challenges, current programs and projects, and water portfolio.

Future Scenarios
To acknowledge that we don't know with great certainty what will happen in the distant future, this water plan update has three plausible yet very different scenarios for 2030, rather than just a single "likely future" condition. Each scenario describes a different base condition for 2030, to which the water community would need to respond by implementing various management strategies. The scenarios are created by varying assumptions about important factors that affect water use and supplies, but the water community has little control like population growth, development patterns, crop markets, industrial productivity, and environmental regulations. The three future scenarios developed for Update 2005 are Current Trends, Less Resource Intensive, and More Resource Intensive.

Resource Management Strategies This water plan update describes a broad and diverse set of 25 resource management strategies. They are available to regions for stronger integrated regional water management to meet future demands and sustain the environment, resources, and economy, involve communities in decision-making, and meet various goals. A resource management strategy is a project, program or policy that helps local agencies and governments manage their water and related resources (see Volume 2 Resource Management Strategies). For example, urban water use efficiency is a strategy to reduce urban water use. A pricing policy or incentive for customers to reduce water use also is a strategy. New water storage to improve water supply, reliability, and quality is another strategy. Each region chooses an appropriate mix of strategies based on its own water management objectives and goals (See Box 1-4 Water Management Objectives).

Box 1-4 Water Management Objectives

To implement these new features, DWR has made, and needs to make, significant analytical changes as summarized in Box 1-5 Analytical Changes.
Box 1-5 Analytical Changes

1-4

OO 

### U.Public Review Draft California Water Plan Update 2005 Volume I - Strategic Plan Chapter I Introduction



## Phased Work Plan and Schedule
DWR will meet Water Code requirements under a phased work plan and develop analytical tools and acquire data for the next update, California Water Plan Update 2010. (See Box 1-2 Legal Requirements for California Water Plan and Volume 4 Reference Guide article "Work Plan for Meeting Legal Requirements for the California Water Plan.") The new, additional data and studies will help regional and local agencies in integrated water resource management.
® Phase 1: Distribution of the public review draft of this five-volume publication marks the end of the first phase. This water plan update is based on the best available data and information and input from an active and diverse advisory committee. Update 2005 recommends policy and priorities, documents gaps in data and analytical tools, and describes an approach for future quantitative analysis. ® Phase 2: This phase began in 2004 and provides a final California Water Plan Update 2005 with revised policy recommendations based on broad public input and numerous public hearings. Phase 2 also documents the data, analytical tools, methods, and assumptions DWR will use in Phase 3. ® Phase 3: Phase 3 begins in 2006 when DWR initiates the process for California Water Plan Update 2010 with participation of a broad public advisory committee. DWR will begin to quantify and evaluate 3 future scenarios and alternative management responses using the data and tools identified in Phase 2. A water flow diagram will present evaluation results for wet and dry year conditions, and a California Department of Food and Agriculture food forecast will be used to estimate future irrigated crop water use for one future scenario.
As part of an ongoing strategic planning process, DWR will present Phase 3 evaluations to the public as they become available. And as a strategic plan, the findings, recommendations, and the implementation plan of California Water Plan Update 2005 will be reviewed and revised periodically. DWR will publish five other water plan updates during this plan's 2030 planning horizon.



## Organization of California Water Plan Update 2005
California Water Plan Update 2005 is organized in five volumes: (1) The Strategic Plan, (2) Resource Management Strategies, (3) Regional Reports, (4) Reference Guide, and (5) Technical Guide. It includes recently compiled water data, information, and studies used to develop the strategic plan. It identifies the most pressing water management issues and challenges affecting the state and its regions. It describes short-term and long-term actions that can be implemented at the state and regional level. It considers future uncertainties, scenarios, and their water demands; and describes a comprehensive set of resource management strategies and an approach for improving data and analytical tools needed to make better water management and planning decisions. All the volumes plus the brochure "Water Plan Update Highlights" and supporting data and information are available on the water plan Web site (htti)://www.waten)lan.water.c,i.L,oN,).

1-5

^m^n^ermil :r^-01California Water Plan Update 2005 Volume I - Strategic Plan Public Review Draft Chapter 1 Introduction Water Plan Update 2005 Highlights This colorful brochure highlights key findings and recommendations of the water plan update and describes foundational actions that must be central to California water management to assure sustainable water resource use. It discusses the initiatives needed to achieve the foundational actions to stimulate progress toward assuring that our water supplies are reliable through 20' 0. It also notes a number of essential support activities needed to accomplish the foundational actions and initiatives.
Volume 1 Strategic Plan Chapter 1 (Introduction). This chapter outlines the public process that figures significantly in this California Water Plan Update 2005. This process will become the standard for future water plan updates. It also discusses new features of this water plan update and describes the organization of the multi-volume water plan update.
Chapter 2 (A Framework for Action). This chapter lays out State government's role in supporting regions through leadership, assistance, and oversight as they assume a central role in California water management. The water plan's strategic plan with vision, mission, goals, and recommendations is described here. It identifies foundational actions, key initiatives, and near-term actions that will stimulate progress toward meeting our water challenges while building a future that assures sustainable and reliable water supply. The near-term actions are part of the implementation plan in Chapter 5.
Chapter 3 (California Water Today ). This chapter reviews California water conditions , challenges, and responses since the previous water plan update. Challenges from regional reports are summarized here and detailed in Volume 3 Regional Reports.
Chapter 4 (Preparing for an Uncertain Future). This chapter examines a new planning and analytical approach for addressing future uncertainties; has discussion of significant factors affecting future conditions; and describes a partial implementation of the new analytical approach, including three future scenarios.
Chapter 5 (Implementation Plan). For the first time, the water plan includes proposals for carrying out its recommendations. Chapter 5 lists the 14 recommendations of the strategic plan and for each one includes specific near-term and comprehensive long-term actions, resources assumptions, implementation challenges, and performance measures. This implementation plan will focus State leadership and guide State and regional actions in managing California's water resources through 2030.
Volume 2 Resource Management Strategies Volume 2 includes narratives for 25 resource management strategies (presented alphabetically). As used in this water plan, a resource management strategy is a project, program, or policy that helps California's local agencies and governments manage their water and related resources. Strategies can be combined in various ways to meet the water management objectives and values of different regions and to achieve benefits for many natural resources. The volume's introduction gives an overview of the 25 resource management strategies and describes how each strategy narrative is organized. Each scenario narrative includes recommendations to facilitate its implementation.

1-6 

## 00 XYV0302Public Review Draft California Water Plan Update 2005 Volume 1 - Strategic Plan Chapter 1 Introduction

Volume 3 Regional Reports Volume 3 includes regional reports for the state's 10 hydrologic regions, the Delta, and a Mountain Counties overlay area, as well as a state summary. Each report includes a discussion of the region: key challenges; ongoing programs; and water portfolio data and information on water supplies and uses for water years 1998, 2000, and 2001.

Volume 4 Reference Guide (The Encyclopedia Water Plan) Volume 4 includes general reference information on California water resources and infrastructure from prior water plan updates and articles prepared for, or related to, this water plan that support material in volumes 1, 2 or 3. In past water plans, this information was interspersed throughout the document. DWR has consolidated this reference material in the Reference Guide to make it more accessible and to streamline Volume 1. The articles are organized by topic and presented alphabetically by title. The Reference Guide will be updated periodically on the water plan Web site (http://www.watemlan.water.ca.,-,o%l).

Volume 5 Technical Guide ( Online Documentation) Volume 5 documents the data, analytical tools, and methods used to prepare Update 2005. The Technical Guide is organized and formatted as a Web site to document the data, analytical tools, and methods used to prepare California Water Plan Update 2005. (For link to Volume 5, go to http://www.waterl2lan.water.ca.gov.)

1-7 

## GOC630 411Jonathan Blees - RE: California RCW Petition ` Request for Reconsideration

From : "Calamita, Christopher" <Christopher.Calamita@hq.doe.gov> To: "Jonathan Blees" <Jblees@energy. state.ca.us> Date : 3/1/2007 3:47:19 PM Subject : RE. California RCW Petition * Request for Reconsideration
Jonathan - Under 10 CFR 430.48(c), if DOE fails to take action on a request for reconsideration within thirty days, the request is deemed denied. The thirty day period for the California request lapsed February 28th, and to date DOE has not taken action Let me know if you have any additional questions.
Chris Calamita Attorney-Advisor Office of General Counsel Fossil Energy and Energy Efficiency U.S. Department of Energy

-----Original Message----- From: Jonathan Blees [mailto:Jblees@energy.state.ca.us] Sent: Thursday, March 01, 2007 6:03 PM To: Bryan.Berringer@ee.doe.gov; Michael. McCabe@ee.doe.gov; Calamita, Christopher; Pinto@hq.doe.gov Subject: California ROW Pe,i,;on ' Request for Reconsideration Importance: High ** High Priority ** Gentlepeople, We have neither seen anything in the Federal Register nor heard from you, so it looks like DOE is denying the request by operation of law under 10 CFR section 430.48(c), by taking no action. Yes?
Thanks.

CC: <Bryan.Berringer@ee.doe.gov>, <Michael.McCabeCq)ee.doe.gov>, <Pinto@hq.doe.gov>, "Lewis, Ronald" <Ronald.Lewis@hq.doe.gov>, "Oliver, Lawrence" <Lawrence.Oliver@hq.doe.gov>. "Belmar, Warren" <W.arren.Belmar@hq.doe.gov> Page 1April 6, 2006

Ms. Brenda Edwards-Jones U. S. Department of Energy Building Technologies Program Mailstop EE-2J Room I J-018 1000 Independence Avenue. SW Washington, DC 20585-0 1 2 1

Re: California Preemption Exemption Petition Docket Number EE-RM-PET-100

Dear Ms. Edwards-Jones: The Gas Appliance Manufacturers Association (GAMA) appreciates the invitation of the U.S. Department of Energy (DOE) to comment on the petition of the California Energy Commission (CEC) for a waiver of federal preemption respecting water conservation standards for residential clothes washers. GAMA is a national trade association representing manufacturers of residential and commercial appliances and equipment whose energy use is regulated by federal law under the Energy Policy and Conservation Act (EPCA). These regulated products include residential and commercial furnaces, boilers and water heaters, as well as pool heaters and gas-fired space heaters. GAMA does not represent the interests of manufacturers of clothes washers and is not qualified to comment on specific technical and economic issues having to do with clothes washers or clothes washer energy use or water use standards. Nevertheless, DOE's decision in the instant matter on whether or not to grant the C EC's waiver petition is very important to GAMA and our member companies. As far as we know, this is the first time DOE has considered a state petition for a waiver of federal preemption under EPCA since the passage of the National Appliance Energy Conservation Act (NAECA), which amended EPCA in 1987. NAECA established very high hurdles that a state must overcome to obtain a waiver of federal preemption. DOE's decision in this matter and its supporting analysis are likely to become precedents for DOE's handling of future waiver petitions. In November 2005, the State of Massachusetts enacted state energy efficiency standards for residential furnaces and boilers that exceed the current federal standards for these products. In order to implement these standards, Massachusetts will have to petition DOE for a waiver of federal preemption. How DOE analyses and treats the CEC's clothes washer petition could impact how DOE handles the expected waiver petition from Massachusetts. GAMA therefore urges DOE to be very careful in considering whether the very stringent statutory criteria for granting a waiver of federal preemption to the CEC have been completely satisfied.



## 0000305Ms. Brenda Edwards-Jones

April 6, 2006 Page 2 In its petition, the CEC reports that the California legislature has required the CEC to establish water efficiency standards for residential clothes washers. (CEC petition at 1) The CEC maintains: "DOE should be very hesitant to second-guess the determination, by the elected governing body of the largest State in the Union, that the standards are necessary." (CEC petition at 27) This is a no more than an attempt to exert political pressure on DOE and create a nice sound bite. Actually, DOE has a duty under EPCA not to rubber stamp state legislated standards; otherwise, the statutory criteria for evaluating waiver petitions would be meaningless. Instead of bowing to political pressure, DOE must look critically at the petition and insist that California meet the heavy burden of proving that the standards are "needed to meet unusual and compelling State or local energy or water interests." In its petition, the CEC reports that six other states besides California that rely on the Colorado River for water supply "are confronting the possibility of a serious shortage." (CEC petition at 11) This raises the question whether California's water interests are so substantially different in nature or magnitude than those of many other states that DOE should even consider granting California a waiver of federal preemption. If DOE grants a waiver to California, these other six states may also feel entitled to the same treatment, with the result being a regional clothes washer standard for the entire Southwest. GAMA strongly opposes regional standards as contrary to the intent of EPCA to create a system of uniform federal standards. EPCA directs DOE to evaluate a state's arguments in support of its waiver petition in the context of the state's energy plan and, forecast or its water supply and groundwater management plan. We have not read the 1998 California Water Plan or the 2005 Draft California Water Plan that the CEC apparently submitted in connection with its waiver petition. We urge DOE to look carefully and critically at these plans to see whether the costs and benefits of residential clothes washer standards, including evaluation of alternatives to such standards, are discussed in these plans. Neither mandates by state legislative bodies nor post hoc rationalizations should be accepted as substitutes for the planning and expert analysis EPCA demands of states that petition for a waiver of federal preemption. Even if a state is able to establish that it has unusual and compelling energy or water interests, the state must also establish that its proposed regulation of an EPCA-covered product is needed to meet that interest. If use of the EPCA-covered product in the state accounts for relatively little of the state's overall energy or water use, a state's claim that state regulation of the product is needed to resolve its energy or water problems should be looked at very skeptically. EPCA requires that states petitioning DOE for a waiver must establish that alternatives to regulation, including reliance on reasonably predictable market forces, are incapable of



## 0000 30 1

,Ms. Brenda Edwards-Jones

April 6, 2006 Page 3 satisfying their energy or water conservation needs in whole or substantial part. In that regard, if the market share or products that would meet the proposed state standard is already high or has been increasing significantly in that state, or even in neighboring states, the petitioning state's assertion that its regulation is necessary should, again, be looked at with a great deal of skepticism. DOE recognizes in its Federal Register notice that "unusual or compelling State or local energy or water interests" are an insufficient basis for granting a waiver of federal preemption if other parties show that the proposed regulation will significantly burden the manufacturing, marketing. ci istribution, sale or servicing of the covered product on a national basis. DOE further recognizes that it may not grant a waiver in any case if other parties show that the state regulation would eliminate product performance characteristics (including reliability), features, sizes, capacities and volumes that were previously available to consumers in the state. We emphasize that this latter restriction concerns adverse impacts on consumers in the state that has petitioned for a waiver. In the instant case, DOE must judge whether the California regulation will make affordable top loading clothes washers unavailable to California consumers. If and when the State of Massachusetts petitions DOE to exempt its furnace and boiler standards from federal preemption, DOE will have to evaluate whether the Massachusetts standards would make furnaces and boilers that can be vertically vented through a chimney unavailable to consumers in that state. In conclusion, out of concern for precedents that may be established for future waiver petitions, GAMA urges DO fl to be very strict in assessing the merits of the CEC's petition. If DOE gives the, CEC any benefit of the doubt on the relevant issues, other states will be emboldened to prescribe their own energy or water conservation standards and to expect to receive the same liberal treatment from DOE. This would lead to a proliferation of state standards that EPCA, as amended by NAGCA, was designed to avoid. Again, we appreciate the opportunity to submit comments in this very important proceeding. Respectfully submitted,

Joseph M. Mattingly Vice President, Secretary and General Counsel 

### GAS APPLIANCE MANUFACTURERS ASSOCIATION, INC.



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### April 5, 2006

Ms. Brenda Edwards-Jones U.S. Department of Energy Building Technologies P rogram Mailstop EE-2J, Room IJ-018 1000 Independence Avenue, SW Washington DC 20585-0121 Re: "California Preemption Exemption Petition, Docket Number EE- -PET-100" The San Diego County Water Authority (Water Authority) strongly encourages the U.S Department of Energy (DOE) to approve the Petition to Exempt from Preemption California's Water Efficiency Standards for Residential Clothes Washers. The federal Register, Vol. 71, No. 24 (dated February 6, 2006) listed a number of issues to which the DOE was interested in receiving comments. The Water Authority is responding to four of these issues.
Are California'

s water interests "

unusual and compelling, " and how do they compare to those of the Nation and other States? 

### As noted in the petition, California has a persistent water crisis. Water demand grows as the population increases, while supplies are dwindling. The growth, economic and regional water supply situation in San Diego can be used to characterize the uniqueness of the unusual and compelling interests of the State of California. The population of San Diego County is projected to increase by 842,300 people between 2005 and 2030, for a total county population in excess of 3.8 million'. This change represents an average annual increase of about 33,700 people, for an annual growth rate of roughly 1.1 percent.2 The Water Authority is a wholesaler of imported water, which consists of 23 member agencies. Our member agencies provide retail water supplies to 97 percent of the San Diego County population. The Water Authority's mission is to provide a safe and reliable supply of water to its member agencies serving the San Diego region. The San Diego region currently obtains approximately 80 to 90 percent of its supplies from water imported from Northern California and the Colorado River. During the fiscal year (FY)

I Draft 2005 Urban Water Management Plan, San Diego County Water Authority ; December 2005; pg. 1- 10 2 Regional growth projections are based on the San Diego Association of Governments (SANDAG) 2030 Cities/County Forecast

A public agency providing a safe and reliable water supply to the San Diego region 

### MWW ON &%-Yaw 

## 00 0 F

### Ms. Brenda Edwards-Jones

April 5, 2006 Page 2 of 7 2005, the Water Authority paid almost $217 million to obtain and deliver these water supplies.3 This dependence on imported water supplies has made San Diego County vulnerable to shortages. Therefore, the Water Authority is taking a proactive approach to diversifying water supplies. Any water shortages resulting in water supply cutbacks would have severe adverse impact on the local economy. Demand for water in the Water Authority's service area falls into two basic categories: municipal and industrial (M&I), and agricultural. M&I uses currently constitute about 80 to 85 percent of regional water consumption. Agricultural water, used mostly for irrigating groves and crops, accounts for the remaining 15 to 20 percent of demand. By 2030, total normal water demands are projected to reach 829,030 acre feet (AF), which represents about a 29 percent increase from the 642,152 AF of demand that occurred in fiscal year FY 2005.4 M&I demand can be subdivided into residential demand (water used for human consumption in the home, domestic purposes, and residential landscaping) and water used for commercial and industrial purposes. Based on SANDAG data, the 2004 composition of San Diego regional housing stock was approximately 61 percent singlefamily homes, 35 percent multi-family homes, and 4 percent mobile homes. The area's diversified employment base includes telecommunications, electronics, computers, software, and biotechnology. High technology and bioscience related employment now exceeds 160,000 jobs. San Diego' s gross regional product was forecast to reach $151.1 billion in 2005, a 6.6 percent increase over 2004's $141.7 billion estimate . The number of people actively working averaged 1.42 million in 2004, and that number was projected to rise by 2.1 percent in 2005, to 1.45 million.5 Compared to the pace of expansion recorded in the 1980s, the current growth is more moderate, and perhaps more healthy and sustainable. Commercial water demands generally consist of incidental uses but are necessary for the operation of a business or institution. Major commercial water users include service industries, such as restaurants, car washes, laundries, hotels, and golf courses. Economic statistics developed by the San Diego Regional Chamber of Commerce indicate that almost half of San Diego's residents are employed in commercial (trade and service) industries. Industrial water consumption consists of a wide range of uses, including product processing and small-scale equipment cooling, sanitation, and air conditioning. San Diego also has a number of water-intensive industrial users, such as electronics and aerospace manufacturing. The tourism industry in San Diego County affects water usage within the Water Authority's service area not only by the number of visitors, but also through expansion of service industries and attractions, which tend to be larger outdoor water users.
3 San Diego County Water Authority 2005 Annual Report; pg. 20 4 Draft 2005 Urban Water Management Plan, San Diego County Water Authority; December 2005; pg. 2-1 5 Draft 2005 Urban Water Management Plan, San Diego County Water Authority; December 2005; pg. 1-9



## 0000305Ms. Brenda Edwards-Jones

April 5, 2006 

### Page 3 of 7

San Diego County agriculture is a $1.3 billion dollar per year industry, eighth in farm production value in the State.6 The coastal and inland valley areas of the county possess a moderate and virtually frost-free climate able to support a variety of sub-tropical crops, making the San Diego area a unique agricultural region. The primary crops grown for the national and international markets are avocados, citrus, cut flowers, and nursery products. To a lesser extent, local fresh market crops and livestock are produced in the Water Authority's service area. In recent years, agriculture has accounted for 10 to 20 percent of the Water Authority's total water demand depending on weather conditions. Irrigated agricultural land in the Water Authority's service area totals 73,769 acres. Agricultural customers are aggressively conserving water because of the limited supplies and the high cost of water. Within the next five years, conservation is expected to make up ten percent of our water supplies. Since 2000, the Water Authority has annually conserved an average of 40,500 AF of water, through both funded conservation programs and legislated standards already set in California. Implementing the Tier 2 water efficiency standards for residential clothes washers in the State will save almost as much water as consumed annually by the City of San Diego, the second largest city in California. Should the phrase "in the United States generally " be interpreted to include comparisons to regions as well as national averages ? Are the water use issues in California substantially different in nature than those prevailing in other western states? 

### Using the plain interpretation of the words "in the United States generally", the comparison between California's interests and the interests of other states should be done in a broad manner based on national averages, not in a more specific manner based on regional comparisons. If Congress had intended regional comparisons to apply, it would have stated this in the statute. In addition, using national averages is consistent with the methodology used by the DOE to establish the Federal energy and water standards. The energy standards set for washing machines do not take into consideration regional and local concerns but were set based on national implications to the average consumer and did not specifically address implications to consumers regionally. When considering the preemption application, the DOE should also note that there was no national standard set for water consumption for clothes washers because the "Department does not have the authority to prescribe a minimum water factor standard." Here, California Energy Commission is applying for a preemption waiver for a Federal standard that does not exist. While the Federal Law states that it preempts State law for energy consumption or water use, the water use factors only apply to showerheads, faucets, water closets, and urinals and do not apply to washing machines. The

6 Draft 2005 Urban Water Management Plan, San Diego County Water Authority; December 2005; pg. 1-8 7 Federal Register Volume 66, No. 9 Friday January 12, 2001, II. D. 7



## 000 C

### Ms. Brenda Edwards-Jones

April 5, 2006 Page 4 of 7 requirement of where Federal law preempts state law is clarified in the Federal regulations that state that a Federal water use preemption applies only to standards set for faucets, showerheads, water closets and urinals.8 Although the intent of Congress was not to compare California's water use to other western states, California's water use issues are still substantially different in nature and magnitude from those in other western states. As stated in the preemption waiver application, California water consumers are currently using more water supply than is available. California has groundwater basins in overdraft, has granted more water rights from Sacramento River Delta than the amount of water that is physically available, and is taking Colorado River water beyond its maximum allotment. California has been instructed by the US Bureau of Reclamation to live within its means as it relates to the Colorado River and is taking a proactive approach to diversify water supplies. Failure to obtain adequate water supplies to replace anticipated cutbacks to the Colorado River supply will result in a severe economic impact to California.

Are there alternative approaches to clothes washer water savings that could achieve the same water savings in California as would be achieved by the California clothes washer standards? 

### Alternative approaches to clothes washer savings are already being implemented. To meet growing demands, the Water Authority and its member agencies have implemented long-term strategies to reduce the region's reliance on imported water by diversifying the supplies portfolio, and maintaining and operating a vast array of critical water facilities and conveyance systems. Following a six-year drought beginning in 1987, the Water Authority began to diversify its water portfolio. The Water Authority's portfolio includes imported water, water transfers, seawater desalination, recycled water, local groundwater, and conservation. The costs for each acre foot of water from these supplies range from $453 to $13,000. Even at the high cost of developing new water supplies from water transfers, sea water desalination, local groundwater supplies, and recycled water, the Water Authority and our member agencies are still proactively pursuing and implementing all of these options. In addition, the Water Authority has implemented an Emergency Storage Project for surface water supplies which, when completed, will provide access to 90,000 AF of water in surface storage to be used for emergencies9 and will maximize use of local runoff from rain events which average less than 11 inches of rain annually. The Emergency Storage Project is a system of reservoirs, interconnected pipelines, and pumping stations designed to make water available to the San Diego region in the event of an interruption in imported water deliveries. The total cost of capital improvements to the Water Authority's supply system over the next five years is expected to exceed 3.2 billion

8 10 CF1t Ch. 11, §430.33 e Draft 2005 Urban Water Management Plan, San Diego County Water Authority; December 2005; pg. 9-2



## 00003:°

### Ms. Brenda Edwards-Jones

April 5, 2006 Page 5 of 7 dollars.10 This does not include the amount being spent by each of our member agencies for improvements to their respective retail water systems. Although San Diego is pursuing all opportunities to obtain a reliable water supply for our growing region, conservation continues to be the most cost-effective measure since it can be obtained at a price as low as $200 for an acre foot of water. The Water Authority is a statewide leader of innovative programs in water conservation. In addition to providing incentives for indoor plumbing, we also have proactive conservation programs for commercial, industrial and institutional sites, outdoor irrigation, and landscape. Our efforts have been so successful, however, that many of the conservation programs implemented in the early 1990s are maturing, including programs for ultra-low-flushtoilets, showerheads, and high efficiency washers. Those who wish to purchase highefficiency clothes washers to save water or because it is environmentally correct have most likely done so. Therefore, we must pursue the next level of customers purchasing clothes washers. A water efficiency requirement in clothes washers would enable us to continue to capture the savings from water efficient machines. The Water Authority has provided financial incentives to consumers to purchase water savings clothes washers since 1994. To date, over 51,000 clothes washers have been purchased through the Water Authority rebate programs. This considerable investment has resulted in a savings of almost 3,000 AF. But we need to have even greater savings, which water efficiency standards will enable us to generate. Clothes washers are the second highest water-using device in the residential household. Having a water efficiency standard for these machines will allow San Diego to recognize even more significant savings. Is California's Petition' s statement that water supplies are not `fungible" and that it is very difficult to transfer any water savingsfrom one sector of the State to another accurate ? Are there ways California can transfer water savings more easily? 

### Although in many cases water savings are not fungible, where those water savings are fungible, agencies in California are transferring water savings from one sector of the State to another. California's water use is intricately linked to high-energy costs and consumption. As the nation's largest water user with a vast water transportation infrastructure, California's water systems are uniquely energy-intensive due to pumping requirements to deliver volumes of water long distances, across mountain ranges, and over high elevations. The State Water Project, the nation' s largest state-built water conveyance system of reservoirs, lakes, power plants, pump stations, canals, tunnels, and a 444 mile-long aqueduct, is the largest single user of electricity in the state. The amount of energy required to support the state's water delivery system and energy requirements associated with treating, pumping, and delivering water from water supply sources to population centers is of increasing concern throughout the state. This cost of delivery can reduce the ability to transfer water from one sector to another. It is clear that more
f0 San Diego County Water Authority 2005 Annual Report; pg. 08

Qoo3."-'

### Ms. Brenda Edwards-Jones

April 5, 2006 Page 6 of 7 efficient water use will substantially reduce and avoid energy costs that would otherwise be expended. San Diego County is the southern- most area of California and, as such, is at the bottom of the pipeline. Eighty to ninety percent of our water is imported from the Bay/Delta in Northern California and from the Colorado River. Supplies from the Colorado River will be reduced when California decreases its demand to stay within its allocation of 4.4 million AF of Colorado River water. To help reduce California's demand on the Colorado River supply, the Water Authority currently partners with the Imperial Irrigation District (HD) to transfer water from agricultural communities to San Diego ' s urban region

. IID will transfer up to 200,000 AF of conserved water annually to the Water Authority. An additional 77,700 AF will he provided through savings from lining the All American and Coachella canals. The cost to transfer water can be significantly higher than that of the regular imported water we receive. The direct costs include the sale price of the water, as well as, the conveyance, storage, and treatment costs. There are also indirect costs to transfer water which may have unintended consequences to other water users, local economies, or the environment

. Transferring water from agriculture to urban may produce extensive crop idling , which can reduce production and employment on both the farm and in secondary economic sectors

. The reduced revenues could affect local governments disproportionately with potential impacts to spending on a wide range of services provided by local government

. In order to implement the water transfer, the Water Authority is expending financial resources to mitigate these economic impacts. 

### Another concern is that the negotiated transfer water cannot be moved when export facilities are already pumping at full capacity. The RD transferred water requires access to the Colorado River Aqueduct owned by the Metropolitan Water District of Southern California, and if the Aqueduct is delivering a full capacity, the transferred water will not be available to the Water Authority. Environmental concerns include the cumulative effects of transfers could impact habitats, water quality, and wildlife. The transfer of IID water creates continuing concern regarding the Salton Sea. Historically, excess water from the farms would replenish the Salton Sea

. Farmers were being called upon to use water efficient practices so the conserved water could be transferred to San Diego. This would have resulted in significant increases in the total dissolved solids concentration of the Salton Sea and could eventually result in the Sea drying up. Increased salt concentrations and a reduced size of the Sea could end an essential stop in the bird migration chain

. Because of this, the Water Authority will be contributing $64 million to the Salton Sea Restoration Fund for environmental mitigation costs

. The total cost to restore the Salton Sea could reach as high as $7.5 billion

. Even with the extensive costs and constraints, the water transfer from TID to the Water Authority is still a critical component of our future water supply.



## 000 0

### Ms. Brenda Edwards-Jones

April 5, 2006 Page 7 of 7

As you can see, California and the San Diego region are exploring every means possible to optimize our use of the State's water supply. Because of the critical water situation in California, we must pursue all alternatives to minimize water use including water savings from optimized washing machines. We respectfully request that you approve the Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers. It is critical to the San Diego region's economy and to our residents' quality of life for generations to
come.

Ken Weinberg Director of Water Resources

t:\Toby Roy\SuPport Letter - Clothes Washer Waiver.doc

### March 29, 2006

Samuel W. Bodman Secretary of Energy United States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Re: Support for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers docket number EE-RM

- PET-100
Dear Mr. Secretary: 

### On behalf of the City of Yreka, we strongly urge you to approve the Petition to Exempt from Preemption California's Water Efficiency Standards for Residential Clothes Washers. California's water use is intricately linked to high energy costs and consumption. As the nation's largest water user with a vast water transportation infrastructure, California's water systems are uniquely energy-intensive due to pumping requirements to deliver volumes of water long distances, across mountain ranges and over high elevations. The State Water Project, the nation's largest state-built water conveyancesystem of reservoirs, lakes, power plants, pump stations, canals, tunnels and a 444 milelong aqueduct, is the largest single user of electricity in the state. The amount of energy required to support the state's water delivery system and energy requirements associated with treating, pumping and delivering water from water supply sources to population centers is of increasing concern throughout the state. It is clear that more efficient water use will substantially reduce energy costs and use. 

### Due to the state's unique water and energy circumstances, California must pursue highly efficient and cost-effective energy and water conservation strategies and solutions. In 2002, the California State Legislature declared that "a significant portion of urban water demand in the state is for residential clothes washers" and that "water conservation is a proven tool that will make the most effective use of the state's limited supply, and will conserve energy." As a result of these declarations, the California Energy Commission adopted water efficiency standards for residential clothes washers to address the unique and compelling interests and needs of California. Implementation of state water efficiency standards will result in significant reduction in use and cost to pump, treat and provide reliable state water supplies while also reducing energy consumption and costs required to maintain and operate water delivery systems and wastewater treatment facilities. The amount of energy that will be conserved as a result of water efficiency standards will be significant. A fully implemented 8.5 water factor standard will save as much energy as the annual usage forapproximately 50,000 California homes, and the 6.0 water factor will save the equivalent

annual energy use of approximately 85,000 California homes. Along with increased consumer energy and water cost savings, these water efficiency standards would not burden the clothes washer industry. Instead, these standards would positively impact the manufacturing, marketing, distribution, sale and servicing of these high efficiency washers. Today, most appliance manufacturers, large and small, already produce these types of high efficiency washers and comply with proposed standards. While 30 percent of California's sale of washers already comply with the 8.5 standard, 20 percent of sales already comply with the 6.0 standard. Various rebate incentive and educational programs throughout the state are also in place to support and increase the sale of these washers and currently account for 39 percent of the market. However, if provided this preemptive waiver, California can achieve a 100 percent market share and increase sales competition and gross revenue of the clothes washer industry. As California uses more water than any state and will continue rapid population growth, we support a residential clothes washer water efficiency standard of 8.5 effective January 1, 2007 followed by a 6.0 standard effective January 1, 2010 to conserve and manage supplies for a growing population. Implementation of these standards will create tremendous water and energy savings for the region while supporting legal obligations to reduce use of imported water deliveries. It is crucial that California carry out these waterefficiency standards and responsibly reduce its dependence on overly tapped and energyintensive regional and imported water supplies. Water efficiency standards for residential clothes washers will help California achieve this goal. We sincerely hope you will approve the Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers. It is critical to the state's economy and quality of life of populations that will make California their home for generations to come. 

### Sincerely,

Kathi Sheehan 

### Special Projects Manager, Water Conservation Coordinator City of Yreka 701 Fourth St. Yreka, Ca. 96097 (530) 841-2356 office (530) 842-3721 fax



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### March 21, 2006

Samuel W. Bodman Secretary of Energy United States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Re: Support for Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers Dear Mr. Secretary: On behalf of the City of Del Mar, we strongly urge you to approve the Petition to Exempt from Preemption California's Water Efficiency Standards for Residential Clothes Washers. California's water use is intricately linked to high energy costs and consumption. As the nation's largest water user with a vast water transportation infrastructure, California's water systems are uniquely energy-intensive due to pumping requirements to deliver volumes of water long distances, across mountain ranges and over high elevations. The State Water Project, the nation's largest state-built water conveyance system of reservoirs, lakes, power plants, pump stations, canals, tunnels and a 444 mile-long aqueduct, is the largest single user of electricity in the state. The amount of energy required to support the state's water delivery system and energy requirements associated with treating, pumping and delivering water from water supply sources to population centers is of increasing concern throughout the state. It is clear that more efficient water use will substantially reduce energy costs and use. Due to the state's unique water and energy circumstances, California must pursue highly efficient and cost-effective energy and water conservation strategies and solutions. In 2002, the California State Legislature declared that "a significant portion of urban water demand in the state is for residential clothes washers" and that "water conservation is a proven tool that will make the most effective use of the state's limited supply, and will conserve energy." As a result of these declarations, the California Energy Commission adopted water efficiency standards for residential clothes washers to address the unique and compelling interests and needs of California. Implementation of state water efficiency standards will result in significant reduction in use and cost to pump, treat and provide reliable state water supplies while also reducing energy consumption and costs required to maintain and

### operate water delivery systems and wastewater treatment facilities. The amount

of energy that will be conserved as a result of water efficiency standards will be significant. A fully implemented 8.5 water factor standard will save as much energy as the annual usage for approximately 50,000 California homes, and the 6.0 water factor will save the equivalent annual energy use of approximately 85,000 California homes. Along with increased consumer energy and water cost savings, -these water efficiency standards would not burden the clothes washer industry. Instead, these standards would positively impact the manufacturing , marketing, distribution, sale and servicing of these high efficiency washers. Today, most appliance manufacturers, large and small, already produce these types of high efficiency washers and comply witn proposed standards. While 30 percent of California's sale of washers already comply with the 8.5 standard, 20 percent of sales already comply with the 6.0 standard

. Various rebate incentive and educational programs throughout the state are also in place to support and increase the sale of these washers and currently account for 39 percent of the market. However, if provided this preemptive waiver, California can achieve a 100 percent market share and increase sales competition and gross revenue of the clothes washer industry. As California uses more water than any state and will continue rapid population growth, we support a residential clothes washer water efficiency standard of 8.5 effective January 1, 2007 followed by a 6.0 standard effective January 1, 2010 to conserve and manage supplies for a growing population. Implementation of these standards will create tremendous water and energy savings for the region while supporting legal obligations to reduce use of imported water deliveries

. It is crucial that California carry out these water efficiency standards and responsibly reduce its dependence on overly tapped and energy-intensive regional and imported water supplies. Water efficiency standards for residential clothes washers will help California achieve this goal. We sincerely hone you will approve the Petition to Exempt From Preemption California's Water Efficiency Standards for Residential Clothes Washers. It is critical to the state's economy and quality of life of populations that will make California their home for generations to come. Sincerely,

Kim Krause Finance Director/Treasurer

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