The Mono Lake Committee
POWER

April 15, 1998

Ms. Jeanine Jones
Executive Officer, Bulletin 160-98 Advisory Committee
Department of Water Resources
Box 942836
Sacramento, CA 94236-0001

Dear Ms. Jones,

Thank you for giving the Mono Lake Committee and POWER this opportunity to comment upon B160-98, the State's draft Water Plan. The Committee has made a preliminary review of the document and is providing these specific comments to you. We also plan to join with others in submitting a broader letter of concern. Please note, however, that we wish to reserve the right to comment in more detail at a later date.

The Mono Lake Committee and POWER believe that the flaws in Bulletin 160-98 are so severe as to warrant additional investigation of the document's methodology and math, and the conclusions that are drawn by DWR. As presented, Bulletin 160-98 fails to provide state leaders and the public with a credible planning tool for making water resources decisions.

We recognize the vast compilation of data that Bulletin 160-98 encompasses and appreciate the effort of the staff in assembling this draft document. However, substantial revisions are needed in order to satisfy the legislative mandate that the California Department of Water Resources (DWR) prepare a final water plan which "...guides the orderly and coordinated control, protection, conservation, development, management and efficient utilization of the water resources of the state." (California Water Code 10004-10011).

DWR unilaterally selects one standard -- development -- out of the six mandated measures as the basis for preparing Bulletin 160-98. The department arbitrarily eliminates from any serious consideration the other five standards by which the adequacy state's water plan must be evaluated: control, protection, conservation, management and efficient utilization of California's water resources.

Bulletin 160-98 is the document that the California Legislature and the public should be able to rely upon for guidance on how to best invest the state's limited capital in managing our water resources. This can only happen if the document presents an accurate, unbiased and clearly documented evaluation of the status of the state's water demand/supply balance and of the full array of options for improving the efficient management the state's water resources.

Unfortunately, as currently drafted, B160-98 falls short of this goal in three fundamental ways:

(1) Flawed State Policy: B160-98 presents such a narrow and limited evaluation of conservation and other water management efficiency measures that it:

• violates the state's legislative mandate;
• underestimates the potential water supply and other benefits that come from more efficient water utilization; and
• overstates the future gap between supply and demand.

The precise numbers are not known because B160-98 is incomplete. However, the underestimate of water efficiency measures could be as much as 1 - 2 million acre feet/year.

(2) Flawed Assumptions: B160-98 relies upon inappropriate assumptions and modeling which:

• biases the analysis in favor of the construction of new storage facilities;
• underestimates drastically the potential of water conservation, recycling, transfers and other efficient water management options in meeting the real water needs of the state; and
• overstates the future gap between supply and demand.

The precise numbers are not known because B160-98 is incomplete. However, the underestimate of water efficiency measures could be as much as 1 - 2 million acre-feet/year.

(3) Misleading Numbers: B160-98 fails to use real numbers in its base case and, without explanation, presents dramatically inflated urban demand figures for both the 1995 and 2020 scenarios which contributes to the overstatement of the gap between demand and supply by as much as 700,000 - 1,000,000 acre-feet/year.

 These problems, described in greater detail below, are significant and must be addressed. As presented, draft Bulletin 160-98 appears to underestimate the potential for conservation and other efficient utilization of the state's water resources and overstate the supply-demand gap by some 2 - 4 million acre-feet/year -- potentially the entire water shortage (with no overdraft) identified by the DWR as existing in the year 2020.

DWR asserts that its "estimates of future conservation are prudently conservative...so that the future gap between supply and demand is not underestimated" (emphasis added, pg. 4-20). However, DWR fails to consider the real cost to Californians of overestimating this gap, ranging from expensive investments in environmentally damaging facilities that may not be needed to the value of lost opportunities for communities to develop more dependable, economically valuable, "drought-proof" water supplies within their own regions.

Important public policy discussions are underway which rely in large part on the conclusions in the current draft Bulletin 160-98, including the CALFED draft EIR/EIS. It is essential that DWR revise Bulletin 160-98 so that these efforts are provided with an accurate accounting of the state's water management options which will help them to reach reliable and supportable decisions for California.

Until DWR revises Bulletin 160-98, the Mono Lake Committee and POWER firmly

believe that the document's conclusions are not reliable and cannot be used as the basis for making any public policy decisions. B160-98 should be withdrawn and re-released only after the analysis has been redone.

Finally, the Mono Lake Committee and POWER would like to offer their support and assistance to DWR in working to revise Bulletin 160-98. Thank you for your consideration of our comments.

Sincerely,

Frances-Spivey Weber
Executive Director

Dorothy Green
POWER

cc: Lester Snow, CALFED