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~1' I OOuG93 Alan Martallero's Comments February 11, 2003 To: Randy Seaholm From: Alan Martellaro Re: Comments to Coordinated Facilities Operations Report My comments are limited to water administration issues as they apply to the modeling efforts and eventual implementation of any alternative. It may be out of the scope ofthis project, but the protocol will need to be fleshed out prior to implementation. This must include the means to convene a forum for making decisions, and the specific triggers (when, how, and how much) that require bypasses or storage releases. This is the responsibility ofUSFWS, with recommendatimis made by the Executive Committee on what the protocols should be. See Service's comments concerning allowing CFOPS participants to opt out of making the 20,000 acre-feet release in average/wet years after droughts. The following is from the draft report (see Ground Rules/Administration 2.2.1 in the draft report). It leaves umesolved the accounting of bypassed storable inflow: During Phase L the issue of how bypassed diversions to storage would be administered has been discussed. Several alternatives for administration exist: . Bypassed diversions to storage would be credited toward a "paper fill" of the reservoir and the reservoir would attempt to achieve a subsequent physical fill using a junior refill right, This is essentially the administration agreed to by the SWAT team and used to decree the Clinton Gulch, Green Mountain and Dillon refills. . Bypassed diversions to storage would not be credited toward a paper fill under an administrative policy such that bypasses are regulatory in nature and the reservoir would attempt to fill later under its own priority. . Bypassed diversions to storage would not be administered toward a paper fill of the reservoir, but would be administered in Division 5 only, and under the PBG, as a regulatory bypass that would not count against thefill of the reservoir. The first two bullets correctly describe the manner in which storable inflows are administered in Water Division 5. The third bullet is similar to the second, but it specifically identifies the PBO as a regulatory bypass. Regulatory bypasses are generally mandatory operating conditions, whereas the bypass for the PBO will be voluntary. Bypasses for the PBO that does not paper fill the storage right will represent an enlargement on the historic operation of the right, and will injure upstream rights and likely injure any junior right in the basin. For these two reasons a regulatory bypass under the PBO will be administered as a paper filling of a storage right. Noted - clarification will be made. Is it certain that CFOPS will be voluntary? P:\Data\GEN\CWCB\19665\Report Phase 2\Technical Memorandum No. 12\Appendix B.doc 1