Laserfiche WebLink
<br />Scopil/g Summary Report <br /> <br />overruns could be viewed as more intentional rather than inadvertent, and penalties <br />rather than just payback may be more appropriate. However, given the inexact <br />nature of large-scale irrigation use, and the difficulties in measurement, Reclamation <br />believes penalties would not be appropriate. ~ ' <br />c- - <br /> <br />]n addition, requiring that extra-ordinary conservation, such as fallowing, be the <br />means for payback, does impose a form of penalty. Regardless of the factors that <br />have been mentioned and all of the unknowns, districts are expected to stay within <br />their entitlements. If they exceed their entitlements, payback must be in the form of <br />verifiable extra-ordinary conservation, rather than a typical weather, or market <br />related, reduction in use. Requiring that payback be from extra-ordinary <br />conservation, such as fallowing, is a significant deterrent, and assures that districts <br />will strive to stay witrun entitlements, using their inadvertent over-run flexibility <br />only when absolutely necessary. <br /> <br />(f) Deve/oping incellhves to minimize overnms: The policy does facilitate mllllmlzmg <br />overruns as use would be monitored and projections of end-of-year use would be <br />made. Water users would be notified during the year if/when Reclamation's <br />forecast indicates they are approaching their entitlement. <br /> <br />(g) Allowil/g vo/wltall} l'ayl'llck starting the year prior to il/itiatioll of "",,,datoll} payback: The <br />proposed policy will revised to include this provision. <br /> <br />(h) Prohibiting IIse of IIoll-system water to payback ovemms that would ill traduce IIoll-system <br />water ill to the Ca/amdo River system: Several of the entities tllat utilize Colorado River <br />water have access to non-system water, such as stored groundwater. By utilizing <br />water from these resources, and forbearing their use of Colorado River water, they <br />can effectuate a payback, without physically introducing non-system Colorado River <br />water into the Colorado River system, As long as the reduced use of Colorado River <br />water can be verified and documf'ntf'd thf' procedure is very similar to an interstate <br />transfer, where an entity intentionally utilizes water from another source, and" <br />forbears the use of Colorado River water, thus making the water available to the <br />arller srate. In the case of an lOP payback, however, the forbearance would not <br />result in more water being made available for direct use, but rather the resulting <br />Colorado River system storage increase would be treated as repayment of system <br />water and would stay in storage for use by all entitlement holders. Should wateo <br />from another river system be physically introduced into the Colorado River system, <br />the potential for environmental impacts due to the introduction of exotic flora and <br />fauna would need to be addressed. <br /> <br />(i) ReqllirinR diverters that report amlllallll to report all a mOlltl/ill basis: Many of the water <br />users who report tlleir use on an annual basis are home owners whose annual water <br />use is not significant, and does not vary significantly year to year. Requiring <br />monthly reporting of tllese uses would lace an unnecessar burden on small-scale' <br />users that woul have margma benefit to the Jar er scale users and Reclamation. <br />However, ere may e other medium scale users, whose monthly water use is <br />significant enough to warrant the monthly reporting requirement. Reclamation <br />intends to separately review the water use of entities reporting annually to <br /> <br />lA, lOP alld Retated Federal Actiol/s EIS <br /> <br />13 <br />