Laserfiche WebLink
<br />", <br /> <br />, <br /> <br />Agenda Item 25 - .Califomia QSA <br />May 19-20., 20.0.3 Board Meeting <br />Page 4 of 5 <br /> <br />1. The fundamental structure of the program to reduce California's water use has changed since <br />the 1999 California Plan documents and the 20.0.0. QSA were prepared, Rather than <br />permanent conservation-based water transfers, the plan is now predicated on land fallowing <br />in the early years of the 15-year program, with an increase in conservation-based transfers <br />late in the 15-year period. Land fallowing is a measure that can be quickly implemented, but <br />also quickly reversed, Furthermore, IID has opposed land fallowing as a permanent measure <br />to reduce water demands, <br /> <br />. <br /> <br />2. The QSA remains subject to four off-ramps before the seventy-fifth year, not two. The 20.0.3 <br />QSA provides that the QSA will terminate in the event of 1) non-consensual termination of <br />the 1998 IID/SDCW A Transfer Agreement; 2) expiration of the Bureau's Inadvertent <br />Overrun and Payback Program; 3) non-satisfa~tion of the Environmental Mitigation <br />Conditions Subsequent; and 4) a Transfer Stoppage. <br /> <br />a, As explained by the California agenci~s, the third off ramp will terminate the QSA in <br />the event that the $243 million in state and local funds is not sufficient for the purpose <br />of paying the environmental mitigation costs outlined in the Environmental Cost <br />Sharing Agreement Currently, environmental mitigation costs are estimated to be <br />$179 million. This condition subsequent was not in the 20.0.0. QSA. <br /> <br />3, "Transfer stoppage" may just another way of providing for one of the objectionable off- <br />ramps in previous versions of the QSA, which was lID's ability to terminate the QSA if an <br />HCP was not completed, It still appears that lID could exercise its right to terminate the . <br />QSA if an HCP is not approved, or if it was not satisfied with the HCP. <br /> <br />4, The 20.0.3 QSA lists over fifteen conditions precedent that must be satisfied before October <br />30.,20.0.3, The difficulty of completing all th~se matters casts doubt on the viability of the <br />20.0.3 QSA, <br /> <br />a, For example, the 20.0.3 QSA provides that all permits and other resource approvals <br />necessary to implement the 1998 IID/SDCW A Transfer Agreement, the conservation <br />by lID of up to 30.3,0.0.0. AFY, and IID's priority 3a cap be finalized, and that all <br />appeals be exhausted. This includes ESA and CESA compliance. The governing <br />board of each entity must approve these measures. Can these resource approvals <br />reasonably be finalized as described? <br /> <br />b. The 20.0.3 QSA also provides that the ,Bureau of Reclamation adopt the Inadvertent <br />Overrun and Payback Program in the !form as attached in an exhibit to the QSA. We <br />were not provided with that exhibit. Overruns that occurred in 20.0.1 and 20.0.2 have <br />not been paid back, The Bureau of Reclamation still must establish an administrative <br />regime that not only assures past overruns will be repaid, but avoids future overruns. <br /> <br />5, Paragraph 9.1 (1) of the 20.0.3 QSA, refers to'a concept of decree accounting averaging that <br />was previously rej ected by the Basin States, , <br /> <br />. <br /> <br />Flood Protection. Water Project Planning anq. Financing. Stream and Lake Protection <br />WaterSupply Protection. COIlf!ervation Planning <br />