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

 EE-RM-PET-100 COMMENT 97
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 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.

0000260

Jamee V. curatelo, Jr. R. Robert NWW Jerome IS1l. Wi lson Randall James Reed KAV71e98

Direcilor

 EE-RM-PET-100 COMMENT 97
Support 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.

0000261

 EE-RM-PET-100 COMMENT 97
Support 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

00002CM

 EE-RM-PET-100 COMMENT 97
999 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 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 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.

0000263

 EE-RM-PET-100 COMMENT 97
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 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 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.

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

 EE-RM-PET-100 COMMENT 97
CALIFORNIA 1'1'6.UNICIPAL

UTILITIES i"^I CSOCIATION

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 Distric t 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.

 EE-RM-PET-100 COMMENT 97
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;6

 EE-RM-PET-100 COMMENT 97
BOARD 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 of Three 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.com

 EE-RM-PET-100 COMMENT 97
Samuel 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 water

efficiency 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

00002Gh

 EE-RM-PET-100 COMMENT 97
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

0000269

 EE-RM-PET-100 COMMENT 97
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

 EE-RM-PET-100 COMMENT 97
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 ^1

 EE-RM-PET-100 COMMENT 97
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 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

OO() G1'4'1 1'i 2

 EE-RM-PET-100 COMMENT 97
Miscellaneous

 EE-RM-PET-100 COMMENT 97
 EE-RM-PET-100 COMMENT 97
If you need this publication in alternate form, contact the Public Affairs Office at I-800-272-8869.

0000274

 EE-RM-PET-100 COMMENT 97
Public 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 75

 EE-RM-PET-100 COMMENT 97
California 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!

0000276

 EE-RM-PET-100 COMMENT 97
State 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

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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

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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

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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

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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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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.

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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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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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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,

California Native Plant Jacqueline Jacobberger, League Wayne Pierson , State Water

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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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

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California 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

Department of Justice California 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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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 TahoeRegional Planning Agency

UFP Unified Federal Policy

UWMP Urban Water Management Plan

WQCP Water Quality Control Plan

WTO World Trade Organization

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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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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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(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 0000294

 EE-RM-PET-100 COMMENT 97
Public 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

xxi

0000295

 EE-RM-PET-100 COMMENT 97
Public Review Draft California Water Plan Update 2005 Volume 1 - Strategic Plan

Chapter 1 Introduction

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.

1-i

0000296

 EE-RM-PET-100 COMMENT 97
Public 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.

1-1

 EE-RM-PET-100 COMMENT 97
California 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 OO29

 EE-RM-PET-100 COMMENT 97
Public 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.)

1-3

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 EE-RM-PET-100 COMMENT 97
California 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

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 EE-RM-PET-100 COMMENT 97
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^-01

 EE-RM-PET-100 COMMENT 97
California 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

00XYV0302

 EE-RM-PET-100 COMMENT 97
Public 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

GOC630411

 EE-RM-PET-100 COMMENT 97
Jonathan 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 1

 EE-RM-PET-100 COMMENT 97
April 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.

0000305

 EE-RM-PET-100 COMMENT 97
Ms. 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

000030 1,

 EE-RM-PET-100 COMMENT 97
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.

000030`:'

 EE-RM-PET-100 COMMENT 97
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4677 Overland Avenue a San Diego, California 92 1 23-1 233

(858) 522-6600 FAX (858) 522-6568 www.sdcwa.org

April 5, 2006

Ms. Brenda Edwards-Jones

U.S. Department of Energy

Building Technologies Program

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

 EE-RM-PET-100 COMMENT 97
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

0000305

 EE-RM-PET-100 COMMENT 97
Ms. 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

 EE-RM-PET-100 COMMENT 97
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:°

 EE-RM-PET-100 COMMENT 97
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-flush

toilets, 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."-'

 EE-RM-PET-100 COMMENT 97
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.

0000

 EE-RM-PET-100 COMMENT 97
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

 EE-RM-PET-100 COMMENT 97
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 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

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

 EE-RM-PET-100 COMMENT 97
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.

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

®0 O:..

 EE-RM-PET-100 COMMENT 97
i It _i1i r '1'!'tlf•r^f9rr !url r i> t!r

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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

 EE-RM-PET-100 COMMENT 97
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

ooo ®..y

 EE-RM-PET-100 COMMENT 97