The Honorable Bruce Babbitt

Secretary of Interior

1849 C Street, NW

Suite 6151

Washington, DC 20240



Dear Mr. Babbitt:



This letter is in response to the Central Valley Project water service renewal contracts that were opened for public review by the Bureau of Reclamation on November 9 and 17, 2000. We are greatly concerned that the contracts, as currently proposed, stand to perpetuate the gross mismanagement of federally subsidized water, discourage water conservation, and inevitably perpetuate the serious over-allocation of California’s limited water resources. We strongly urge the Department of Interior to amend the proposed contracts to ensure that the Central Valley Project Improvement Act of 1992 is accurately and legally implemented, and that the last acts of the Clinton Administration work in a positive direction towards real and lasting California water policy reform.

 

As they are currently written, the contracts will perpetuate the large financial burden the CVP has placed on taxpayers, and make it virtually impossible for the beneficiaries of the project to repay the $2 billion in outstanding debt still owed the government before the 2030 deadline mandated by the Coordinated Operations Act of 1986.



Furthermore, the policy that was intended to encourage the wise use of water and/or raise funds for environmental remediation (i.e. tiered pricing as mandated by the CVPIA) will be rendered all but meaningless in the proposed round of contracts. In line with the CVPIA, the proposed contracts apply tiered water pricing when water consumption exceeds 80% of the annual contract maximum. However, the Department rarely delivers the annual contract maximum, as stated in the contract and demonstrated by historical deliveries, thereby making tiered water pricing ineffective. Historical deliveries have usually amounted to only 65-70% of the Contract Total. We recommend that contracts set the annual contract maximum at the more realistic levels, not at levels that the CVP will not be able to achieve. Otherwise, the antiquated water pricing policies that have encouraged sustained overconsumption will continue at the expense of environmental, and other beneficial water uses.



We are also concerned that the terms of the proposed contracts all but guarantees a second 25 year water contract. In recognition of the constantly evolving needs of California’s diverse set of water users, it seems unwise to simply guarantee contract renewal without clear accountability provisions on the part of the water contractor, a rigorous public review process, and thorough analysis of California’s water needs in the future.

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It is also entirely unclear how water allocation commitments made during the Department of Interior’s contract renewals will be coordinated with water commitments made in the CALFED Programmatic Record of Decision signed in August, 2000. Existing commitments as part of the CALFED process include 15% higher deliveries to south of Delta exporters and 380,000 acre feet of water to be used for the Environmental Water Account, along with CVPIA statutory environmental water obligations. Without coordinated action between the CALFED decision making and Central Valley Project contracts, there will be severe pressure to further increase Delta exports and thereby perpetuate California’s alleged “water crisis.”

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We strongly urge the Department of Interior to amend the proposed contracts to ensure that the Central Valley Project Improvement Act of 1992 is accurately and legally implemented, that the Department coordinate with CALFED decision-making, and that the last acts of the Clinton Administration work in a positive direction towards real California water policy reform. If the Administration cannot reach contract renewal agreements that include the policy recommendations contained in this letter, we ask that the contracts not be signed.



Sincerely,



Jonathan Randall

California Water Project Coordinator

Taxpayers for Common Sense



Angela Sherry

Research Associate

Environmental Defense



Byron Leydecker

Chairman

Friends of Trinity River



Gerald H. Meral

Executive Director

Planning and Conservation League



Stan Griffin

Regional Vice President

Trout Unlimited of California



Drew Caputo

Senior Attorney

Natural Resources Defense Council



Steven L. Evans

Conservation Director

Friends of the River



Francis Spivy-Weber

Executive Director, Policy

Mono Lake Committee



Cynthia Koehler

Legal Director

Save San Francisco Bay Association

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