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3379 (Jensen/Walter Supplement 2003, p. 6 and Figure 6.6, p. 7). Jensen/Walter conclude from the data that the effect of increasing water supply, with little change in crop evapotranspiration, is increased tailwater quantities (Id. Figure 6,7, p. 8). The historic diversions of Colorado River water by lID (Table of lID diversions in Factor 9; see also MET: Scott, 2003, Table I) demonstrate that the average diversions for 1990 to 2002 (3,lO6,386 acre-feet) represent all / /% increase over the average diversions from 1980-1989 (2,788,839 acre-feet), Increased diversions resulted in a significant increase of tail water flows from lID (Jensen/Walter Supplement, June 2003, p. 12) As also shown from Ihe tabular information in Factor 9, the increasing trends in diversions over the periotl of time after a variety of conservation projects had been phased in over the period 1987 to 1990 under the IID-MWD Water Conservation Program. This program is estimated to save liD over 100,000 acre- feet per year and should have resulted in a COll1lllensurate reduction in diversions, while allowing lID to continue to serve the needs of its farmers, Jensen and Walter indicated in 1997 that the trends in reported data from liD show that the distribution system improvements and general operating practices in lID have reduced some conveyance losses (Jensen/Walter 1997, p, 35). Project management as it relates to water orders, records of water orders and monitoring of amounts of water delivered relative to actual water needs appears to have declined in effectiveness since 1987 (ld,), Jensen/Walter conclusions related to water management, as described in their 2002 report, were that the increasing trends in diversions "... indicates that on- farm water management has changed little over the past 13 tol4 years in liD at a time when available irrigation technology has been improving". Another aspect of liD's Operating Practices has been raised as part of this determination. The Imperial Group have raised issues in their submittals that suggest liD diversions have remained high because they produce substantial revenues from the generation of electricity at liD hydroelectric facilities (Maloney, 2003, p, 2). The Imperial Group represents interests that own or fann approximately 30,000 acres of land in the Imperial Valley, The relationship between diversion amounts and power generation benefits was noted by the SWRCB in 1984, which in 1984 lOO,OOO acre- feel of water would generate $464,900 in revenue for the lID, (Decision 1600, p. 7) Revenue from power generation has increased significantly in the past two decades. liD itself asserts that reductions in diversLons will result in substantial loss of revenue from generatLon (Jesse Silva Declaration, Feb, 2003, p. 36). Based on available infomlation, Reclamation cannot make a detelmlllation as to whether these assel1ions by the Imperial Group are accurate. Generating electricity, as a by-product of the delivery of such amount of water as is necessary for irrigation and potable purposes is pennissible under liD's contract However, ordering and diverting water in excess of irrigation and potable use requirements for the purpose of generating electricity is nol authorized under liD's July 2, 2003 28 Detenninations and Recommendations For lID - Calendar Year 2003