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HomeMy WebLinkAboutMinutes - March 16, 1999 SS218 CITY OF LODI INFORMAL INFORMATIONAL MEETING "SHIRTSLEEVE" SESSION CARNEGIE FORUM 305 W. PINE STREET TUESDAY, MARCH 16,1999 An Informal Informational Meeting ("Shirtsleeve" Session) of the Lodi City Council was held Tuesday, March 16, 1999 commencing at 7:00 a.m. ROLL CALL Present: Council Members — Nakanishi and Land (Mayor) Absent: Council Members — Hitchcock, Mann and Pennino Also Present: City Manager Flynn, Deputy City Manager Keeler, Public Works Director Prima, City Attorney Hays and City Clerk Reimche Also present in the audience was a representative from the Lodi News Sentinel and The Record. TOPIC(S) 1. Water Supply Update ADJOURNMENT No action was taken by the City Council. The meeting was adjourned at approximately 8:30 a.m. ATTEST: R..e Alice M. ftei i�the City Clerk yOF� .r OQ COUNCILCITY OF LODI • • 4</FOAM AGENDA TITLE: Water Supply Update MEETING DATE: March 16, 1999 (Shirtsleeve Session) PREPARED BY: Public Works Director RECOMMENDED ACTION: None — Information only. BACKGROUND INFORMATION: City staff and staff from other water agencies will be presenting an overview of water issues in San Joaquin County along with some specific items for future City Council action. The tentative presentation outline and presenters are as follows: Introduction Richard Prima_ Overview of main problem — groundwater depletion Introduction of participants San Joaquin Co. John Pulver Major County -wide issues Organizations involved Recent Board actions and policies American River water rights filing East SJ Parties Anthony Saracino Activities of ESJPWA Overview of groundwater management City of Lodi Richard Prima Amendment to ESJPWA Memorandum of Understanding Water Supply Master Plan Coordination with Wastewater Treatment Master Plan Cost issues Questions/Comments z'j� Richard C. Prima, J . Public Works Director Attachments RCP/lm cc: Water/Wastewater Superintendent John Pulver, San Joaquin County Water Resources Coordinator Anthony Saracino, ESJPWA Executive Director Bob Johnson, Water Advisory Commission representative Lodi District Chamber of Commerce San Joaquin Council of Governments Tony Goehring, Economic Development Coordinator Rad Bartlam, Community Development Director APPROVED: H. Dixon Flynn -- City Manager `� WTRSPPLYUPDT.DOC � 03/10l9� 3 Year Average: Rainfall and Groundwater Level Change —m— Rainfall —s GW Level Change 29 28 27 26 25 24 0) 23 N 22 U 21 U C 20 19 (� 18 C 17 '(ti 16 15 N 14 13 N 12 > 11 Q 10 L 9 (ts i" e 7 (y) 6 5 4 3 2 1 0 LA 0) T M LO n a) T M Ln Il- 0) r M to I, - to (0 (D r- t` I- r r co 00 00 00 00 0) O) 0) 0) O) m 05 m M 0) a) 0) Q) 0) 0) Q) 0) 0) 0) 0) 0) 3.0 2.5 2.0 1.5 1.0 0.5 0.0 -0.5 -1.0 -1.5 -2.0 -2.5 -3.0 -3.5 -4.0 -4.5 -5.0 Frank\WelsW95 1999 SAN JOAQUIN COUNTY WATER ISSUES Institutional Issues In San Joaquin County, there are 17 water districts, seven cities, 54 reclamation districts, 26 county service areas dealing with water, and the County. To find uniform positions among these entities still remains a significant challenge in dealing with water issucs in San Joaquin County. Groundwater Management Groundwater management means a coordinated use of surface water and groundwater to meet the public need. In addition to the institutional issues involved, there is a lack of adequate scientific information regarding groundwater. Groundwater management will include the tasks to identify the supplemental source of surface water to offset the shortage of groundwater, particularly on the east side of the County. Proiect Financing All aspects of developing an adequate water sapply will require significant expenditures to achieve the resolve. Cost items include; additional studies and analyses, environmental studies, public information and project financing. State Nater Resources Control Deard Issues The State Water Resources Control Board is currently in a process to obtain the water supplies necessary to meet Delta water quality standards. The hearings affect all watcr sources within the State. Considerable effort is being put forward to clisure that not only County water supplies, but County water quality is protected. C,NL>FFD The CALFED is a coalition of State and Federal agencies that fire mandated by the Secretary of the Interior and the {governor of California to "fix" the Delta. Sianiticant funding, from bath State and Federal sources, has been made available to implement projects which will restore the ecological health of the Delta. As much of the Delta is within San Joaquin County, these efforts and issucs will have a large impact on meeting lono term water needs for San Joaquin County. we:.1c :vrn ass COMMON ORGANIZATION'S AND ISSUES RELATED'TO WATER RESOURCESIi'LOOD CONTROL ACTIVITIES FEBRUARY 8, 1999 Advisory Walcr Commission (AWC) - A 19 -member Board -appointed Commission that represents all water management entities, Cities, an at -large member, representative of Fish and Wild i.ilc interests and a member of the Board of Supervisors. San Joaquin County Staff Water and Flood Control. Coordinating Committee (COORD. COIN -1.) - This is a meeting of the staff of agencies included in the Advisory Watcr Commission and other interested parties. Its purpose is to identify issues of Coutttywide concern and, if necessary, bring the issues to the Advisory `Vater Commission for recommendations on policy issues. Board hater Committee (BWC) - A Board of Supervisors appointed Committee, including two members of the Board of Supervisors, which meets to consider issues to be brought to the Board and to obtain inforniation inn current water resourceslflood control issues. East San Joaquin Parties !'Vater Authority (ESJI'WA) - An organization of seven San Joaquin County governmental organizations in the northeastern part of the County. Their mission is to develop a joint project with Fast Bay Municipal Utilities District and other water planning issues. The governmental organizations are Woodbridge inigation District, forth Sart Joaquin Watcr Conservation District, the City of Lodi, the City of Stockton, Stockton Fast Water District, Central Sail Joaquin Water Conservation District and the San Joaquin County Flood Control and Water Conservation District. San .Ioaquin Area Flood Control Agency (SJAFCA) - A joint powers authority of the City of Stockton, San Joaquin County and the Flood Control and Water Conservation District, It has a four -member Board, consisting of two members of the Board of Supervisors and two members of the Stockton City Council. Its purpose is to complete the construction of additional flood control facilities in the Stockton i%4etropolitan Area. Flood Control and Water Conservation District (FC&WCD) - The Countynkidc District formed under State law which is led by the Board of Supervisors. ,%lokelumnc River Watcr and Power Authority (v1RWFA) - An Authority formed by San Joaquin County and the Flood Control and Water Conservation District. 'Che Authority's mission is to develop water -related projects on the Mokclumc River. Flood Control Zone 9 - A zone of benefit formed through the Mrthority of the FC&WCD and approved by the voters for the purpose of maintenance of flood control facilities within the Zone. The lone covers a large arca in the central part of l astern San Joaquin County. Flood Control Zone 10 - A gone of benefit for the purpose of maintenance and flood control in Northeastern San Joaquin County. The District hws been formed under the authority of the Flood Control and Water Conservation District. Reclamation District No. 17 (RD 17) - RD 17 is responsible for levees pru(ectint the arca south of Stockton along the San Joaquin liver. The area includes Weston Ranch, the County hospital and jail facilities, and areas to the south. The County, under contract, provides levee maintenance services to RD 17. Water Investigation Zone 2 (NVIZ 2) - Water Investigation 'Lone 2 is a Countywide zone of the Hood Control District. funds from the "Lone are used for water resources coordination, special studies and investigation. 1 -he Zone expires on June 30, 2000. County Water Policy -'Elie County Water Policy has provided the foundation of agreement anluno the varied water interests within the County. Water Implementation Plan - The Water Implementation Plan is an outline procedure that defines tasks necessary to implement the County Water Policy. CALFED - A consortium of five State agencies and five Federal agencies with management and regulatory responsibility in the San Francisco Bay -Sacramento -San Joaquin Delta. CALI:FD was established to develop a long-term solution to resolve problems affecting the Bay Delta. Department of Water Resources (DWR) - The Department of Water Resources is the primary State agency involved in Statewide water planning and the operation of the State Nater Project. State Water Project (SWP) - The State Water Project is primarily the California aqueduct with numerous other State storage and distribution facilities. State Water Resources Control Board (State Board) - This Board is a quasi-judicial Board who has authority for the allocation of water and the enforcement of water management issues. Regional Nater Quality Control Board - There are nine Statewide Regional Boards who have the responsibility to enforce regulations related to the maintenance of water quality in the waters within the State of California. San Joaquin County is in the Central Valley region. Corps of Engineers (COE) - The COL- is the primary f=ederal agency involved in the construction, maintenance and provision of emergency services for flood control facilities. The COF is also responsible for the enforcement of some Federal water quality regulations. United States Bureau of Reclamation (USBR) -The USI1R is the primary Federal agency involvt!J in conveying and providing water to the Central Valley Project customers. Central Valley Project (CVP) - The CVP is the Federal water conveyance and storage facilities designed to meet Federal watcr dcli%'cry Contract. Federal I:;mcrgency Minaacment Agency (FEMA) - The FFMA is an agency responsible for setting standards regarding flood protection and for administration and enforcement of the National blood Insurance Program. Federal Energy Regulatory Commission (FERC) - This Commission issues a license for hydraulic facilities which generate power. As part of the license issuance, downstream flows are established. Environmental Protection Agency (EPA) -'phis is the Federal agency which administers federal law regarding water quality requirements. The EPA sets standards for all waterways within the l;nited States. California Department of l? tsh and Game - This is the State agency which has the responsibility to protect fisheries within the water of the State of Calilbrnia. That responsibility is extended to include flow and water quality requirements. U.S. Fish and Wildlife Service - This is the Federal agency which is a counterpart of the California Department of Fish and C,amc. - San Luis and Dclta-Meudota Water Authority - An organization of eater customers of'the [mined States Bureau of Rechunation that takes water from the San Luis and Dclta :Mendota Canal. The San Joaquin County office is located at the Fedcral'I racy [lumping Piattt and the Water District in San Joaquin County, and the City of Tracy is a part of this Authority. National Marine Fisheries Service (NMrS) - A Fcdi:ral agency which deals with fishery issues. Primarily responsible for the uccan fisheries. DeltaKeeper - A private organization independently funded, which is dedicated to the tnaintenance of water quality in the Delta. State Recinmation Board - This iS OIC'State Board appointed by the governor,which generally acts as the local sponsor of Federal projects and has regulatory authority over decisions made regarding impacts on project chaimels. N1okelumne River association -A non-political association c,l'interest and agencies which are responsible for water matter rLlated to the Mokelunine River. -3- i .. AB 3030 GROUND WATER MANAGEMENT MANUAL ELEMENTS OF A GROUND WATER MANAGEMENT PLAN Produced by: Ground Water Committee Association of California Water Agencies MARCH 1994 1 AB 3030 THE GROUND WATER MANAGEMENT ACT GROUND WATER MANAGEMENT PLAN ELEMENTS AB 3030, the Ground Water Management Act, authored by Caiifornia State Assemblyman Jim Costa (D -Fresno) and signed into law in 1992, lists 12 components that may be included in a ground water management plan. Each component would play some role in evaluating or operating a ground water basin so that ground water can be managed to maximize the total water supply while protecting ground water quality. Department of Water Resources' Bulletin 118-80 (pg. 9) defines ground water basin management as including planned use of the ground water basin yield, storage space, transmission capability, and water in storage. Ground water basin management includes; (1) protection of natural recharge and use of intentional recharge; (2) planned variation in amount and location of pumping over time; (3) use of ground water storage conjunctively with surface water from local and imported sources; and, (4) protection and planned maintenance of ground water quality. The 12 components listed in Section 10753.7 of the Ground Water Management Act (AB 3030) form a basic list of data collection and operation of facilities that may be undertaken by an agency operating under this act. Data collection will provide information to evaluate the water resources in the basin within the boundaries of the district. The construction of facilities will allow operation of the basin to protect ground water quality and to maximize the water supply by means of recharge of surface water and extraction of ground water at appropriate times and locations. Specific comments about each of the 12 items listed in Section 10753.7 are included in the discussion that follows. For specific information about any issue, contact the Association of California Water Agencies, the California State Water Resources Control Board, the U.S. Environmental Protection Agency, or the California Department of Water Resources. Names and telephone numbers of appropriate experts are listed at the end of each discussion. GROUNDWATER MANAGEMENT PLAN ELEMENTS AS SET FORTH IN AB 3030 10753.7 A groundwater management plan may include components relating to all of the following: a) The control of saline water intrusion. b) Identification and management of wellhead protection areas and recharge areas. c) Regulation of the migration of contaminated groundwater. d) The administration of a well abandonment and well destruction program. e) Mitigation of conditions of overdraft. f) Replenishment of groundwater extracted by water producers. g) Monitoring of groundwater levels and storage. h) Facilitating conjunctive use operations. i) Identification of well construction policies. j) The construction and operation by the local agency of groundwater contamination cleanup, recharge, storage, conservation, water recycling, and extraction projects. k) The development of relationships with state and federal regulatory agencies. 1) The review of land use plans and coordination with land use planning agencies to assess activities which create a reasonable risk of groundwater contamination. 3 SUMMARY OF SUPPLY OPTIONS (Subcategories, i.e. "A1 ",are for categorization only and do not represent a ranking of any kind) CATEGORY A - MORE FROM CONSERVATION Al: Keep -up Successful Water Conservation Program • Continue enforcement measures A2: Expand Public Information Program • More education for general public • More education for agriculture • More in -school education • More education on: =:> plants sprinkler systems (including- timers) xeriscape landscaping • Focus on large users, i.e. restaurants • Refer customers to others that demonstrate lower water use A3: Expand Promotional Programs • Offer free residential audits =:> mandatory, if City thinks there are leaks or wastes =!> voluntary, if owner requests it • Offer rebates for residential upgrades to low flow toilets c • Offer commercial/industrial water audits => customers should pay for the program • Develop financial support programs to allow public customers (parks, schools, etc.) to retrofit facilities with water conserving hardware A4: Expand Water Meter Program • Options: =--> institute a volunteer meter program (not a mandatory one) meters for all uses _ meters for luxury water users (i.e. pool owners) => meters on all remaining commercial facilities meters for all new connections add meters when -pipes are replaced for older homes or when service lines are replaced add meters at time of sale for residential, commercial and industrial customers • Water rates should be based on usage have a base rate and a surcharge for flagrant water wasters A5: Continually Evaluate Internal City Overations for Additional Conservation Potential • Frequency of fire hydrant flushing • Leak detection and repairs of City pipelines Lodi Water Supply Workshop July 26, 1998 Summary of Supply Options I Summary2.doc CATEGORY B - RECLAMATION / RECYCLING BI: Consider Use of Graywater • Evaluate onsite use for irrigation Provide incentives for => providing graywater systems with new residential, commercial and industrial construction => retrofitting older homes and facilities with graywater systems 132• Consider Use of Reclaimed Municipal Wastewater • Evaluate a dual water system for the City • Evaluate sending treated wastewater back to town • Evaluate constructing one or more water stripping plants (wastewater treatment plants) in town • Irrigate parks, schools, golf courses, median strips • Use for construction water C Definitions Graywater: Wastewater from sinks, showers, dishwashers, clothes washers, etc. Graywater does not include wastewater from garbage disposals, toilets or urinals. Reclaimed (Recycled) Municipal Wastewater: Recycled water is the treated product of a municipal wastewater treatment facility, which includes all treated domestic wastewater. Lodi Water Supply Workshop July 26, 1998 Summary of Supply Options 2 Summary2.doc CATEGORY C - LOCAL SUPPLY OPTIONS Cl: Work With Agriculture to Reduce Groundwater Use • Support irrigation district increase use of surface water to reduce pumping • City and/or County should pay/provide incentives to farmers to look at alternatives to using groundwater • Purchase rights through a crop incentive program • Develop a drip irrigation incentive for ag to promote surface water use • Work with North San Joaquin Water Conservation District (NSJWCD) to promote ag users converting to surface water since they are Northeast of City • Financially support ag use of surface water C2: Encourage Surface Water Use In General • Promote infill and discourage urban sprawl • City to insist on maintaining greenbelt between Stockton and Lodi, keep ag on surface water • Save winter rain water and use for non -drinking purposes • Prohibit the construction of lakes in new developments C3: Consider Groundwater Recharge • Use stormwater for recharge • Use river flood flows for recharge • Keep Lodi Lake full year-round for recharge • Develop a recharge program =:�- inject water in wells or percolate in basins =* in City and surrounding area • Recharge facilities around the City using Woodbridge Irrigation District (WED) water C4: Make Effective Use of WID Water • New Woodbridge Dam • Use WID water for parks (Lodi Lake, Beckman Parks, Peterson Park and others that are located within a reasonable distance from WID facilities) • Take Mallard Lake (Lakeshore subdivision) off of groundwater and require them to use WID water primarily C5: Acquire New Water Rights • Obtain new sure water rights => Look to further away places to make claims on water (mountain counties, irrigation districts, delta, etc.) to accommodate the City's future needs => Look to nearbv irrigation districts to obtain water rights to accommodate the City's future needs • Aggressively pursue getting East Bay Municipal Utility District (EBMUD) pipeline water from other areas • Acquire water rights from WID as land is annexed • Mini dams on the Mokelumne River Lodi Water supply Work -shop July 26, 1998 Summ-y of Supply options 3 Summary1doc CATEGORY D - BASIN -WIDE SUPPLY OPTIONS DI: Work With Agriculture to Reduce Groundwater Use • Work with NSJWCD =:> District could store water underground => District has surplus water rights Joint projects with irrigation districts D2: Encourase Surface Water Use In General • Toughen growth & water restrictions e Construct holding basins or reservoirs to store available surface water D3: Consider Groundwater Recharge • All entities in the County should be going after water rights and evaluating recharge options D4: Acquire New Water Rights - • Mini dams on Mokelumne River for diversion use D5: Become Part of Other Aeencies' Proiects Support increasing size of Pardee and constructing Auburn Dam for storage • Work with EBMUD or work independently to make better use of Mokelumne River flows • Pursue American River water from EBMUD's planned pipeline for recharge • Regional dual water system to make use of drinking water and treated wastewater • Bring Delta water to the City => need a treatment plant and pipeline • Build water fund for future water supply and treatment projects Lodi Water Supply Workshop July 26, 1998 Summary of Supply Options 4 Summary1doc Composition of City Demand Industrial Parks 4.7% Commercial/ Institutional 12.9% Multi -Family ;idential 14.5% Single Family Residential 57.8% W U) F Q G� 0 v ,a 0 Oa J q� L- R O3: U r 0 ca CL 0 CL O O O O O O O O O O O O O O O to 'R C7 N r O N CO) I N t I N M � N Iy N I N M N 1 f L \ M s J1 I / I I t M � M orn N M 1 ; It 6661 866L L66L o 9661 5661 0 P66 £661 2666 t661. 6666 6866 CL 8866 c 1861 m CL 9866 CL S86L O ti861 � e86 G • L861 • 0866 6166 O 8161 :3 1161 a 9161 s16 L � P16 L o F - X16 L I 2161 1 1161 01 L O O o o O 61 O (O N M N I4 City of Lodi, Public Works Department City of Lodi's Water Conservation Program Benefits (Condensed from a study reported to the Lodi City Council August 12, 1993.) History The City of Lodi's Water Conservation Ordinance and Program have been in effect since 1977. This is one of the few conservation programs in the Valley that has remained continuously in effect. School Education Program The popular Water Science Educational Program was introduced to Lodi elementary schools in 1986. This program supplements and advances Lodi's total effort to conserve water with science demonstrations/presentations taught in public and private elementary classrooms with the objective of teaching water awareness and water conservation techniques. 263 classes were given inl998. Effectiveness of Program To more accurately determine the reduced water usage, Lodi was compared to three area communities which had only voluntary or inconsistently enforced water conservation regulations, and also had reliable water use data going back to 1980 through 1993. The averages of these three communities were used to determine a "background level" of water use reductions due to drought publicity and minimal water conservation efforts. It should be kept in mind that Lodi probably started at a lower water use rate in 1980 than the other three communities due to Lodi's already existing water conservation efforts. The reductions in water use for the three area communities were averaged then subtracted from Lodi's total water savings. This results in a net saving of 3.52 billion gallons since 1980 or 293 million gallons per year. Pumping Savings The most direct conservation cost saving was in electrical costs. The 1992-93 electrical cost of pumping water in Lodi was approximately $115 per million gallons. Therefore, from 1980 through 1992 electrical cost savings alone totaled $404,856. Other cost savings (not quantified) include decreased maintenance, repair, and replacement costs to wells, pumps, and motors. The cost of the entire Water Conservation Program, adjusted to 1993 dollars from 1979-80 through 1991-92, totaled only $210,342. Reduced Number of Wells Needed A well costs up to $500,000 to explore, test, drill, develop, equip, and lay water mains to the distribution system (this does not include treatment costs). The 1976 and 1990 water master plans had Lodi needing approximately 26 wells with a population of 54,000. The City of Lodi has been meeting the water demands in Lodi with a total of 24 wells (22 active and 2 standby) at a population of 55,000. Therefore, if the City required the 26 wells as projected in the 1976 and 1990 water master plans there would be at least two additional wells needed at this time. At today's cost, that would be up to $1,000,000 (without any treatment). Abandoning water conservation efforts only delay these expenditures. Wastewater Treatment Savinqs Another significant benefit of the citizens of Lodi's water conservation efforts has been the reduction of wastewater flows. These calculations show savings of nearly $240,000 from 1987 through 1992. More significant is the effect on treatment plant capacity. Reduced wastewater flows may extend the life of the most recent $10,000,000 expansion two to four years. H:\FRB\WINWORD\FRANKIWATERCON\Con Ben S=99.doc 1999 SAN JOAQUIN COUNTY WATER ISSUES Institutional Issues In San Joaquin County, there are 17 water districts, seven cities, 54 reclamation districts, 26 county service areas dealing with water, and the County. To find uniform positions among these entities still remains a significant challenge in dealing with water issues in San Joaquin County. Groundwater Mana$cment Groundwater management means a coordinated use of surface water and groundwater to meet the public need. In addition to the institutional issues involved, there is a lack of adequate scientific information regarding groundwater. Groundwater management will include the tasks to identify the supplemental source of surface water to offset the shortage of groundwater, particularly on the east side of the County. Proiect FinancinE All aspects of developing an adequate water supply will require significant expenditures to achieve the resolve. Cost items include; additional studies and analyses, environmental studies, public information and project financing. State Water Resources Control Board Issues The State Water Resources Control Board is currently in a process to obtain the water supplies necessary to meet Delta water quality standards. The hearings affect all water sources within the State. Considerable effort is being put forward to ensure that not only County water supplies, but County water quality is protected. CALFFD The CALFFD is a coalition of State and Fedcral agencies that arc mandated by the Secretary of the Interior and the Governor of California to "fLK" the Delta. Significant funding, from both State and Federal sources, has been made available to implement projects which will restore the ecological health of the Oclta. As touch of the Delta is within San Joaquin County, these efforts and issues will have a large impact on meeting long term water needs for San Joaquin County. ww_VC u-T'.l as COMMON ORGAN I ZATIONIS AND iSSUFS RYLATUYTO WATIER RESOURCESIFLOOD CON'. rROL ACTIVITIFS FE BRUARY 8, 1999 Advisory WaferCommission (AWQ - A I -nwmbcr Board -appointed Commission that represents I at-largr, nicinber, mprfsentakiv of Fish a d Wil i all water managernew emilics, pities, 4� S 11 Wild I fic interests and a 1"Cinber of the Board of Supervisors. Sate ,loaquin County Suff Watcr and flood on ref Coordinating Comiuittee (COORD. COM) - -Mis ii a mcetiiig of die staff of agencies imiuded in the Advisory Walcr Commission and offier italea ted partics. Ttg purpose is to identify issues of Countywidc concera and, if necessary, bring the issues to the Advisory Water Coninussion for recommendatloyls, on policy issues. Hoard Water Comrnilftv (BWQ - A Board of Supervisors appointcd Committeel. including two members of the Board of Supervisors, 1ii(J) meas to consider issues to bt brought to the Beard and to obtain infom)afiop i m current water resources/flood Qontrol issum East San JoaqiAia Parties NVatjQr Authority (ESJPWA) - An organization ofs-eve'll San Joaquin County govtrnnicnt al organizations in the northeastern part of the Countye Theirmission iq to develop ajoint project with Fast Bay Municipal Utilities District and odder water plaraiing issucs, The govertuiientaf organizations are Woodbridge Irrigation District, North San Joaquin Water CorisQEvation District, ibe City of Lodi, the City of Stockton, Stockton Past Water Distsict, Ctmral San Joaquin Water Consenation District and the San Toaquin County Flood Control and Water Con5ervation Dlsuim San Jwllquin Area Flood Control Agency (SJAFCA) - A joinT powors auLl-lority of the City €3f Stockton, San Joaqi)in Cowity and the Flood Control and Water Con,,ervatiorw District. It hasa four-mcmber Board, ;, ' onsisting of two members oB f the oad of Supervisors and two mcmbeys of Elie Stockton City Cuun-61, Its 1)urpose is to complete thQ constniction of additiori-at flood control facilities in the Stockton Mettopolitan Area. Flood Control and Water Conservadou District (FC&WCD) - The Countywide Oistrict formed order Slam law to ch is 1,:d by the Board Of SUJ)UViWTS, Mokelurnric River Water and Powcr Authority (MRNYPA) - An Authority formed by Sana Joaquin Cowity and the Flood Cmilrol acid Water Canscrvation District, The Authority's mission is to doveloP water-reiatod projects on the XfQkclunw� River, Flood Control Zone 9 - A zone of benefit formed through the authorityof the FC:`. WC and approved by the voteni. for the purposc, of rnaimenance of (lood control facififies Nvillih, the 7taa1e. Tho Ione covc-5 a large area in the central pan of Fastcra San Joaquin Counly. Flood Control on 10 - A 4011C OfbeMfit for the purpose ofniaintrnance wid flood contrO in Nonheaslern S411 Joaquin Counly. The Distr4;t. has been forrocd undcr the ;authority of the Flood Control anj wats�r Conservation District, ReiHamafion District No, 17 (RD 17) - RD 17 is VC13polUilb[C for levti�s plutWilig LhC w7Ci South of Siockion along the laza Joaquin River. I'he area Includes Wt�stpn Ranch, the County Hospital and jail facilities, and areas to the south, The County, ,eider contract, provides levet, maintenance services to RD 17. Water Investigation Zone 2 (WIZ 2) - Water Investigation 4onc 2 is Lt Cotwtywidc zone of 1130 Flood Control District, I'imds from the one ars used for waicr Testa irces coordination, special studies and investigation. the Zone expir" on June 30, 200 County Water Policy �The Courtty Water Policy has provided the foundation of agreenicat among Thtu vied waterin(erws within dle County. Water Implemenfation P13n - The Water Niplementation Man is an outlinc procedure that defines tasks aer-essary to implement the County Water Policy. CALFED - A cunsortivm of five Statc agencies and fiveFcdaral agencies with mana9cment and regulatory responsibility in the San Francisco Bay -Sacramento -San Joaquin Delta, CALFE'D was I established To develnp a long-term solution to msolve problems affwing the Bay Dclta. Department of Water Regourco (DWR) - The Department of Water Rcsources is the primary Statc agency involved in Statewido water play rng and the operation of the Stag W;itcr project Slate Water Project (SWP) - The Stag Water Pr(�Jmt is priu-taffly air, California miucduct with iiurnerous other Stau, strata and distribution rhoilitie's, State, Water Resources Control Board (State Board) - This Board is a ql)asi-judicial'Bu and who 11,15 authority for the allocation of water incl the enforcement of water inxiagement issws. Regional Water Ounlity Conti ol Board - There are nine Slatcwide Regional Boards %V110 have tile re-sponsibi)jty to elaforce regulations related to flic of water quality in the wat.Qy-s witEn The Statz OrCalifomia. San Joaquin Counly is in the Central Valley region, Corps ofE agincers (COE) -The COC is the primuy FtdcTal agency involved in thQ 1ons-lruction, gnaimenam:e alld pmvision of enicrgency ser-.,;ce& for flood control faelhtics. The COC is also Y�,,spoxv6hle for dic �n)fbrcenient of sonic Frdcral water quality regulations, United StatcN Bureau of RvOaivatiot (USDR) -Thtz USIAR, is the primary Federal',igency involved iii convcying and providing watet, to dic Contra) VaflcY Project centrill Valley Project (CVP) - The CVP is the Federal water conveyaoce and stomgc facilities designcd to meet Fcdcral vvawr k1clivery colitract. M Vele a I-oncrge tcy Managment e ncyEMA.) - The FFMA is zmag.cncy resp.€ nsibJu for seffin sw ndarcl.s regardiag flood protection mid for admitii:"tt-£alon and MforMlIeiit tit' he National Hood Insi.trame Prsaga°ataa. Federal Energy Regolmory Commission ;MI CA - This Commission issues a 11€aewse for hydraulic 1111ihtios whic:la genexatc power. As part of the hj` e se i',SLUITICi, i-iownstrelani Paws are csta lishe.d_ tf ir€a trt rtt l 'car .ei rrAgency (EPA) _ "llnis is tl Fcdvnd agency which adn)inisters Fcdcral lase rcgarding water quality r .tduircmcttts. The EPA ., tr, standards for all vvawi°w ays within the 1_ trait sl ,lilies, California Depiminient offish is and Fume - This is this Statc aage ncy which has the respc n'..;I ?idi ty to protcrt fisheries Willi in the water of the SIaLe of'C tlifiorziia, That at respcynsibility is axten dca to include flow and watcr cltt,tlity recl.wKmenta, S- Fish and Wildlife Service - This is the Peroral -agc cy which is a uou tc.cpart ofthe Caiitbruia Dcpgartment Of Fish, and Oan-10, Sin Luis and Dclta.-Mendota Water Authority - An organization of water customers of the Lttniwd slaleN Bureau ofReclamation that talcs water from the San Luis and Delta -Meadow Canal, Vic San Joaquin County office is locawd at the F€ndoral Tracy Pumping Plant and the Watcz Dlstric;t its Sari 'lo aqui nourityg'7tid tlaC City gid° Tracy is a part of tkai� Aastlmr!ty, National Ktriinc Fisheries Service ( F ) - A Fedcral gciwy vv3 icb deals with tis-h€^ry issnaes_ Primarily responsible for the occau fisheries, DehaKe per - A privatc orgaanizatioa itadepcndcntly tii€ de d„ whicit is dedicatcd to the maxtitemmecn of ,,vatcr quality in the Delm St -ate la tictt .. €ci ®"£11i is tlnc Stme Board appointed by the governor, which gcn(�rally acts €Jl loo a1 5tacsa sor OrF doral pr'sijmts and Inas regulaaLory authority over do r:isk)vs made, rcgm ming itnlpaacta Oil project Cl1,3tnt165. N-Tokulumne River Association - A anon -political association ol`isitmst and al"ertcirs which ars: responsible for water 'niatt r rolawd to t1at: Mokelumne River. w yOF� �', 00 MEMORANDUM 4<JFOR� TO: Honorable Mayor and Lodi City Council Members FROM: Alice M. Reimche City Clerk DATE: March 17, 1999 SUBJECT: 1932 'Water Fight' This subject came up at the March 16, 1999 shirtsleeve session during the water supply update discussion. I thought you might be interested in some basic information and a recap of this incident. AMR/JLT cc: Public Works Director Prima t MEMORANDUM, City of Lodi, Public Works Department TO: City Manager FROM: Public Works Director DATE: August 4, 1977 SUBJECT: 1932 "Water Fight" At the reaular Council meeting of July 20, 1977, as part of the review of the "Water System Analysis and Master Plan Reevaluation," it appeared that some members of the City Council were not familiar with the 1932 water fight. The purpose of this memo is to inform them of this lawsuit, since it is not discussed in detail in the Master Plan Re- evaluation. The attached "MEMORANDA ON JUDGMENT AND DECREE, CITY OF LODI VS. EAST BAY MUNICIPAL UTILITY DISTRICT" is a summary of the final judgment and decree which was rendered March 17, 1938 in San Joaquin County Superior Court. This is the "legal restriction" referred to in the Water System Analysis and Master Plan Reevaluation, pooes 1-1 and 5-1. i Very briefly, the "water fight," as it is called, was a suit brought by the City of Lodi I against E.B.M.U.D. and P.G.& E. in the early 1930's. The complaint was essentially that E.B.M.U.D.'s and P.G.& E.'s actions regulating the flour of the Mokelumne River were detrimental to the City's water supply. The original suit was heard in 1932 and a judgment and decree made in 1933 in Lodi's favor_ It was cppeoled to the California Supreme Court, which ordered the Superior Court to rehear the case. The attached sum- mary is based on this second trial. As pointed out in Chapter 5 of the Water Plan, the adequacy of the City's water supply is a topic much beyond the scope of the Report. If the City Council desires additional information of this water fight, it is felt that this topic should be set for a future shirt- sleeve session, and should not be discussed in detail of the shirtsleeve session -of August 9, 1977, at which time Trotter, Yoder & Associates will be reviewing the "Wafer System Analysis and Master Plan Reevaluation." It is recommended that this information be forwarded to the City Council prior to the next shirtsleeve session. Jac L. Ronsko Public Works Director Attachment �•ti:r:•: J.'. r.. .. .. ..illi ._ .. _ A' % _-,!-C' uJ n•.r n T� J. 1 L J!` :J! • •PAL ,l n T'^ C T Late of jud�,:�ent ;",'arch l?, 193�. This cecr <<: 1'n;:� ti:�:f.; ct:e City of Lodi has a vest -.ed right to appropriate it► m-aximum of b,GQG,OC'G Zallon.,: per bay, and acre feet per rear from wells located iiithin an area slightly over b sq. mmiles. This area is shown in blue on the attached `lap. Tnese 36DO acre feet -per year is e uivalent to ar'. : ver _ _ ::,f 3,`rwUans per. Clay. This ri.,ht is supei'_or to t'.•. e I'i � .t;, J- LhF 1-1=:ci_ is _'us aiid Electric Comoany and file -astll } "iunicipal except as follolfc. I. The Pacific, Gas and Electric Co; an has a Trio; " ri.,:t t0 take. cn(- G7vo r 75 cubic _rcvtpC=GCO:G 01 - from t'f1B Port: ior!: of the i o'..eluMrze o °,:i;ic'z not to exceec} 30 cubic - per :rCCO:11i;iav cc coil'vay-e.d and disi:r'ibuto`' •tier ,,unicip- Ll, do-zestic and other fi•.—net i.cial -uses in tI-C- Citit.: of Jac' --, on, Slitter Creak,- and reak,and in tneir vicinities." I=. To tare am d di vert from t:ae 1 or th Fork o f the I.:oke1umne. . river 135 cubic feet per second--anc? to convey said water and dis::har.�e -thy.: sa ys into the so-called ; etty rorebay Reservoir, trio Sz._id ,,iter in +he o: zr,:tion of the said Electra ro?•ier Plant, . IIT. The rigi?tS to sl.ore .,-aTLer iri seve.1 reservo-Ji. aTt0 use in tP.e o.�ar� ion of this ::.loctra ?o7 -ter Plant: -1- I". The decrce pecif id's ;1„?i_ u:1 releases to th c^. avain ..:tan:ial of tj:e 1-%okelu' ne- Fiver, suci''i minimu::t releases d.e7en'Can upon th0 :22it1 rc'l -arn-ivai run-ofi Of ti2e ztrean— The iust BBaly ;it iii y, %= Strict shall not be required to take any s, ecus for the protection of Lodits water Supply unless an rd unci.',. the st :1. tiC .round Saar level in Lodi Ts -t•:.lIs -:i thin the U sq. imile area fulls to a point below sea level.- `f1.1 -i > Static z-oartd water level shell be �.c certc_red b de` ,,e .• ,L y �er-�lninb the u 2r�_oe level in wells within the area. b maasuremert.._ made d1=44 -m- the .first ten days of January of each year. �'.han the static level dhotis belowsea level for t::0 successive J?Lluo.z'yrS, tit°3 res7on:a� bili`j *asses t0 ,tS.t' aSt 71-, i.Urti: i;);7.1 li�ilit;� irtriC'i.icOr tj e ITtaiL�- tenance of Lodi t s priority. Lodi shall maintain its and g(7I:iG :2 it% :i.n `Ootid Oi:Arc% ti condit;'Lon; anOL if it ? 3 unable LO Pump wttf�:icient water of good r;u lity Co develop tete rights z•yferre� 'Go above, the East st T)a,v i Unlcipal Util_t�� �.? strict Si13ls ;supply its o:','n expeA se the differor:cea between th- ctnount produced b” Lod -l's we11.5 within the disurict a -rid in the amount decreed to the. City by the court. If -the Fast t=ay '!un 4 cilal Utility District fails to COM -ply r:Tith these provisions, the decree re ;wires tdha district: to -:release water into t;2P='�okelumne 'river from its stora_e faCil1t16S. The F -201_111t the district shall release varies with -'Che u'a•.n-nuaZ rti-n-0,11T n a ` "" G3:.t 1 Of tf:^. �iOf2i:t`1,�e hiV�i', .S S'E:uJa11e^�.0. at the t:Ok81U�r;v ei2l! Station: or annual x•urorfs loss than 25u,C-0'J acre feet per year t'cis rclease shall be not less than 117,0CJO acre feet;_ for annual r:nJf equal LO Or �;re.atC'r aha: C"}.00 OGv acre feet the raleasa s(,sll be not; lc:i,. tt1cl t j J t, i c1CrY, i Oct 1) r f-.: r, in addition LO -2- these releases the mast 'ap ?.?.:nicipal Util_ty District shall also release i!cid.itional flot;;s for flushing the �o'Lelu�^:ze c�ha n—ne , T�:ese flushing; discrar�rres are not require:. if the E•ast Bay Utili,.p istrict elects to s,zp;:)ly- the -„ter required to ;;i'iro the City of Lo-dit.. vlater u.-,) to the ca.moun: specified in t• la ` lie- 0':11;??tion of the East ':ay municipal UtIl.ity to supply Such :leiter deficiencies or to make such releases from, stora�,e as specified in the decree s'^,'.'?l not arise if the d_strict establishes to the sat' sfsction o i th- e courr. i'that any . fall of the static water leve'l. in. iJl.a inti f l ,,. -,ells b -,1-0 -1-i Said C?_';vsr point o: sea lek el i:. ca_sa:.. u -r than said C'cfendant Soa\ C llunicin3l Utility 1'1str_ct. j tindLr r= .t.t.s which are junior in priority to thoss of st;id. defend—'ant'. The East Jay . unicipal Utilit�' riser- �t h -.as tt._le right. to take froit its Pardea Da:a 310 cub-;: feet per secoliG or a-PrOX- imately 2'-'0,00t7,,CC?') a.-all.on ? -z-!r fid f . This is ey"i v alc-_t . 0 J� �. 0' `` re f 3P.�, ��r f2.1; J. ! 5'J ;23S C? C 2'irl t approxio,atel , to_ ' L':.. _ ' wt��= UZVYie�i� t.c• ^.i T.... .�c :,i:: t•:),i �•i• and the r'i_L '.cennZ dv.f of July a total of 217,0J"/ acre feet o-`' ':ia%: _ I'.'?!' 1:ne .`Osie"Lun;Le River. -3- ='_�-- � � __� -� = � - -�;� - - -- ���"�� _ _ �� � � __-� - - - -- � ;` � ��,� �= � �� � -�.�� � �� � �` r � � ;.�, _� � _ -� -� � .. � _ -� �� :. �� �-�_ _ `-_-._ }� No. 22,415 JUDGMENT AND DECREE In the Superior Court of the State of California, in and for the County of San Joaquin. CITY OF LODI, a municipal car por- atioa, Plaintiff, vs., EAST Bal. MU- `ICIPA. , UTILITY DISTRICT, a pub- lic corporation, PACIFIC GAS -UND ELECTRIC COMPANY, a corporation, et al., Defendants. The above entitled cause havin: been duly and regularly tried before the Court sitting without a Jury. a Jury having be=en waived, and tha Court having heretofore duly made and sil-ned its dectsiou herein, com- prising findings of fact and conclu- sions of law, wherein and whereby judgment and decree were awarded to the plaintiff ai hereinafter set forth. ' Sow, therefore, in accordance with said findings and conclusions, IT IS 1 HEREBY ORDERED, ADJUDGED i AND DECREED: FIRST: That plalnfiff, City of Lodi, a municipal corporation, by virtue of its own appropriation and by virtue of its prescriptive use as against the claims of the overlying land owners iu 7 the Mokelumne basin, has a legal vest• ! ed right to appropriate, pump and di- vert the waters percolating through the water -bearing strata which under- li-s said Mokelumne basin in the Coun-ty of Ssn Joaquin. State of Californi2. which basin Is fed by the waters of j the Mokelumne River, to the eaten; of a maximum diversion of 6,000:000 gal4Dns per day, and 3,600 acre feet i per year; that it Is plaintiff's right to take and divsrt such water through Weill situate within the limits of said City of Lodi and owned, leased or op - erased by said plaintiff: that such right of the plaintiff is prior in time and superior in right to any claim of appropri=tion that the defendants, or either of them, have to waters of the Nfokel_mne River, save and except the t right of the defendant Pacific Gas and Electric Company as specified in par- a. ar• .graph Second her_of: that subject to i said priorities of defendant Pacific Gas and Electric Company, as set fortis in paragraph Second of this De- cree, the title of plaintiff to the ap- propriative right hereinabove adjudg- ed to b'- vested in it is hereby quieted against bath defendants herein; that the defendants and each or them are I hereby prohibited and enjoined from interrupting the flow of the Mokelum- ne River in such a manner or to such an extent as will prevent or interfere i with an average annual replenishment and percolation into the Lodi zrea in said 'Mokelumne basin equivalent to that which would occur under nat- ural conditions, and in order to pro- vide such an average annual perrola. tion into said basin from the waters of the Mokelumne River as would oc- cur under natural conditions. and. in order to avoid such interference, said defendants are severally required to regulate and release the fI•ow of said '%Iok=elumne River as hereinafter pro- vided. SECOND: That as against plaintiff, defendant Pacific Gas and Electric Company has vested rights to store, divert. release, regulate and use the waters of the North Fork of the 31oke- lumne River and its tributaries as par- ticularly set forth in sub -paragraph (D) of .paragraph III of the addttionai_ defense In its amended and supple- mental answer, and also in paragraph V of tate said additional defense, but limited and restricted as specifically found in paragraph XVII of the afore- said findings of fact, which vested rights, as so limited and restricted. are more particularly described as fol- lows: (1) The right to take and divert from the North Fork of the Nfoke- lumne River 55 cubic fest per sec- ond of the water naturally flow- ing in said river at all times of the y-e:r, augmented when neces- sary in periods of loco flocs- by the waters impounded in the reser- voirs hereinafter in this paragraph Second mentioned; to convey and distribute so much of said coater as may reasonably be required (but not exceeding 30 cubic feet per second thereof as a maximum) for municipal, domestic and other beneficial uses in the Cities _ of Jackson. Sutter Creek. and in their VICinitie9; to discharge the residue of said water into U3 ;aid Tabeaud Forebay Reservoir. and to use said residue in the opera- tion of its Electra Power Plant. (2) The right to take and divert from the North Fork of the Ntoke- lumne River 135 cubic feet per second of the water naturzlty flowing In said river at all times of the year, augmented when nec- essary in periods of low flow by the waters impounded in the said reservoirs in this paragraph Sec- - oud mentioned, and to convey said waters and discharge the satne in- _ to the so-called Petty Forebay Reservoir, and to use said waters in the operation .of the said Elec- tra Power Plant. (3) The right to store and im- pound at all times of the year the Waters of the North Fork of the Mokelumne River and its tribu- taries in the foliovdag reservoirs to their full capacities, and to use the water so. stored for aug=ent- i^_g the flow of the said North Fork of the said river; and to use said water in the operation of the said Electra Power Plant, and fcr distribution and We in Jackson. Sutter Creek, and vicinity. to the extent and for the uses aforesaid. The said reservoirs and their ca- pacities are as follows: a. Upper Blue Lake Reser- voir of a storage capacity of 7700 acre feet of water: b. Lower Blue Lake Reser- voir of a storage capacity of 43.40 acre feet of water: c. Twin Lakes Reservoir of a storage capacity of 1340 acre feet of water; d. Meadow Lake Reservoir of a storage capacity of 6110 acre feet of water; e. Bear River Reservoir of a storage capacity of 6712 acre feet of water; f. Tabeaud Forebay Reservoir of a storage capacity of 1153 acre feet of water: and Petty Forebay Reservoir of a storage capacity of 12 acre feet of water. (4) The right (under the so- called Jackson and Volcano Ditch rights) to divert from Tier Creek, Mill Creek. Antelope Creek and Panther Creek. tributaries of the worth Fork of the said Moke- lumne River, all the waters of said creeks at all times during the year to the extent of a maximum flow of 30 second feet of water, and to use the said water for the genera- tion of electric power at and above the so-called Electra Power House. . That the rights of tate said defend- ant Pacific Gas and Electric Company. in this paragraph SECOND adjudi- cated, ars prior in time and superior to the rights of the plaintiff and the said rights of said def -adapt are here- by quieted against the plaintiff. THIRD: Defendant Pacific Gas and Electric Company is the owner of cer- tain permits granted by the Divisioa of Nater Rights. Department of Puh- tic Works, of the State of California, described in paragraph VI of the ad- ditional defense of said defend=nt's amended and supplemental answer, and all rights existing under and by virtue thereof, to appropriate the waters of the North Fork of the llokelumn-z River and its tributaries for use in the generation of electric power, ana also is the owner of the license grant- ed by the Federal Power Commis:4= described in paragraph VII of said additional defense of said answer. De- fendant Pacific Gas and Electric Com- pany has and shall have, subject to the conditions expressed in this para- graph and in paragraph Fourth here- of, the right, and is hereby obligated and required so long as it maintain:; and -or uses the Salt Springs and -or Lower Bear River and -or Deer Valley Reservoirs. (a) to impound and store, each year during periods of flood and high flow, in said Salt Springs Re:,- ervoir, and in said proposed Lower Bear River and Deer Valley Reser- voirs, if and when constructed, so much of the flood and seasonal high waters flowing in said North Fork of the lrokelumne River and its tributar- les as may be necessary to fill said reservoirs to their capacity: (b) by means of outlets, control gates and other works already provided at said Salt Springs Reservoir, and to be pro- vided at said Lower Bear River and Deer Valley Reservoirs. if and when o3nstructed. to releasa, each year dur- ing periods of low flow, the craters impounded and stored therein: (c) by means of so impounding and stor- ing water in, and releasing water fora[. said reservoirs, to regulate the flow of water in said North Fork so that such water may be economically and efficiently used for the operation of said defendant's existing and pro- posed electric power plants located on said North Fork at and above Electra: (d) to divert and use, when desired by said defendant for the generation of electric power at its said existing and proposed power plants, so much of the water flowing in said North Fork, including water released front its said Salt Springs Reservoir, and from Lower Bear River and Deer Valley Reservoirs, it and when con- structed, as may be required for the economical and efficient operation of said power plants; and (e) to return and discharge each year into the main channel of the Mokelumne River at or Above Electra all water diverted by it from said North Fork, including the water stored in all its existing and proposed reservoirs, except only the water to be conveyed to Jackson, Sut- ter Creek, and their vicinity in the ex- ercise of the water rights described hereinabuve in paragraph Second, anti except the carry-over storage of 20,000 acre feet hereinafter mentioned. FOURTH: In exercising the rights described In the foregoing paragraph Third and complying with the oblig-, tion imposed upon it by said para- graph Third, defendant Pacific Gas and Electric Company and its succes- sor; in interest shall have the right. and are her --by obligated and required to observe and comply with the follow- ing conditions, viz.: 1. In every year in which pre- cipitation of rain and snow shall equal or exceed the normal amount, as defined below, said de- fendant (a) shall never diminish the quantity of water which would naturally flow in said North Fork of the Jlokelumne River at the diversion dam for the proposed Electra Conduit to less than a daily average of 500 cubic feet p_r second, by impounding or divert- ing to storage any water in said Salt Springs Reservoir or in said proposed Lower Bear River Reser- voir or in said proposed Deer Val- Ity- Reservoir; and (b) whenever conditions of storage and run-off p_rmit, shall release front otte or more of any of its aforesaid exist- ing and proposed reser5airs a suf- ficient quantity of water to make the daily average flow at the di- vtrsion dam for said Electra Con- duit equal to at least 300 cubic feet per second whenever the quantity of water which would then naturally be flowing in said North Fork at said Diversion Dart sltfll be less than a daily average of 500 cubic feet per second; pra- vided, however, that such release of water from storage shall not re- duce the aggregate quantity of water stored in all said defend - art's existing and proposed reser- voirs to less than: 1121,000 acre feet at the end 'of June 91.000 acre feat at the end of July 56.000 acre feet at the end of iagtl3t 58,000 acre feet at the end of September 40,000 acre feet at the end of October .",0.000 acre feet at the end of November 20.000 acre feet at the end of December 10,000 acre feet at the end of Jarman lit even year in which pre- cipitation of rain and snow shall be les3 than the normal amount. as defined below.. said defendant (a) shall approximate, so nearly as practicable. the standards of operation specified in clauses 1 (a) and 1 (b) above; (b) shalt never diminish the quantity of Rater which would naturally flow in said `Orth Fork of the Make- lumne River at the diversion dam for said Electra Conduit to less than a daily average of 000 cubic feet per second during the months of May. June and July nor to less than 200 cubic feet per second in any other month, by imp)uading or diverting to storage any water in said Salt Springs Reservoir or in said proposed Lower Bear Riv- er Reservoir or in said proposed Deer Valley Reservoir: (c) shall release from one or more of all its aforesaid existing and propos-. ed reservoirs a sufficient quantity of water to make the dally aver- age flow at the diversion dam for said Electra Conduit equal to at ltasc 300 cubic feet per second during the months of June. July, :august and September, and at least 200 cubic feet per second in all other months, provided that conditions of run-off and storage will permit, and provided further that the quantity of Rater stored in all said reservoirs shall not be reduced to less than 10,000 acre feet before the end of January. 3. Said defendant shall return and discharge into the [Hain chan- nel of the Mokelumne River at or above Electra each year. subject to the provisos in clauses 1 (b) and 2 (c) above, all nater stored and to be stored by it in said Salt Springs Reservoir. and in said proposed Lower Bear River and Deer Valley reservoirs, if and when constructed, and shall before the end of each year return and discharge into said Mokelumne River alt other water diverted by it from said North Fork of the Mokelumne River, except only the water which shall he conveyed to the Cities of Jackson, Sutter Creek and their vicinities for ben- eficial use in the exercise of the water rights described in para- graph Second hereof, and except the carry-over storage specified in Subdivision (1) of this para- . graph. (9) The amount of precipitation shall, for the purpose of this para- graph. be deemed to be normal when the average of accumulated seasonal precipitation as measur- ed at [Vest Point and in the vicin- ity of said Blue lakes is not less than the equivalent of I3 Inches cf nater by the end of January; incites of water by the end of February; °S inches of water by th? end of March. 29 inches of water by the end of April; and 30 inches of water by the end of May. For determining the amount of precipitation at West Point the precipitation records as reported by the United States Weather Bu- reau Station for that place may be used, and if for any reason the United States heather Bureau should discontinue such measure- ments. then said defendant shall stake them each year. Said de- fendant is hereby directed t.J sieasure accurately the preciptca- tion in the vicinity of Blue Lakes; provided that if. after- sufficient records have been obtained. it shall 2ppear that the measured precipitation at some other station on the Mokelumne River water- shed or an adjacent watershed, or the average precipitation at more than one station on the lloke- lt:mne River watershed or an ad- jac--nt watLrshed, bears a definite relation to the average of the pre- cipit2don at Nest Point and Blue Lakes, theft the measured precil.. !cation at the aforesaid station or stations Wray be substftated for the measured precipitation at West Point and Blue fakes as a means for determining when a season It to be deemed normal or subnormal within the meaning of this paragraph Fourth. The plaintiff and defendant East Bay District shall be furnished with copies of all records of measure- ments and estimates of precipita- tion and runoff made by said de- fendant as rapidly as they are completed, and shalt have the right to inspect the measuring ap- paratus used. The obligations im- pos=d upon defendant Pacific Gas and Electric Company under para. , aph Fourth of this decree are conditions attached to its . right and title and that of its succes- sors in interest to maintain and -or use the Salt Springs, Lower Bear River and Deer Valley Reservoirs, or any of them, under the water diversion and storage permits ap. pertaining thereto, and shall not be a oantinuing obligation upon said defendant and/or its succes- sors in interest it it or they should abandon the ownership and oyer. ation of said three reservoirs in the future, and a sale or transfer of said reservoirs and water rights pertaining to the same shall re- lieve the vendor or transferor of such obligation and impose it up- on the Vendee or transferee as the case may be. FIFTH: That the defendant Fast Bay Municipal utility District is here- by ordered and directed to measure the flow of the 11okelumne River. and to release at and below its Pard" dam into the Channel of said river, the waters thereof In conformity with the following primary schedules, viz.: (1) It the runoff of the Mokelumne River is less than 250.000 acre feat in any one calendar year. as measured at the measuring station of the United States Geological Survey immediate[y upstream from the Pardee reservoir, presently known as Mokeluntne Hili Gauging Station, quantities of Nater shalt be released sufficient to mat:t- tain an average daily rate of flow in the different months of each calendar year as follows: DtiRING THE MO\THS OF: January, 51) second feet; February . ............ 50 \[arch . ................100 : nett/, .................... 00 May 200 2- June . .................... 251) July, 1" August . ................ _ 250 September , .......... 250 ctober. ................ 0 November, 100 " December, 50 " Provided that it the total runaf, so measured shall be less than 120,000 acre feet Par year, the entire flow of the river shall be released during said year at rates of flow approximating the foregoing as nearly, as may be. (2) When such annual runoff, so measured. is equal to or greater than 250.000 acre feet, but is less than 300,- 000 acre feet, then such releases shall be maintained at the following aver- age daily rates of flow, to -wit: DURING THE MONTHS OF: January . ................ 50 second feet: February . ............ 50 March, ..... .._.100 " 200 May . ......................200 .. June . ....................250 July . ......................30i August . ................30 P rr Se tember....__.._._50 � r „ ctobcr. .............. 200 November, 100 " December. ..._..... 50 (3) When such annual runoff. so measured, is equal to or greater than 300,000 acre feet. but is less than 350,000 acre feet, then such releases shall be maintained at the toll -awing average dally ratas of flow, to -wit: DURING THE )NIO\THS OF: January . ................100 second feet: February . ............100 " March . ................104 aprlL .................. _ 200 May, June .300 .................... July ............... .. Augast. .300 September, ...._..�00 October, 250 " November. ........104 December, ..........100 (4) When such annual runoff, so measured, is equal to or greater than 350,000 acre feet, but is less thar. 400,000 acre feet, then such releases shall be maintained at the following average drily rates of flow. to -wit: DURING THE MONTHS OF: January . ................140 second faet: February . ............104 March .............. 100 April . ..................... _"00 May . ....................300 June . .................... 4 JU July . ....................400 August,404 ............... September, ^00 " CGJber .............. _.J 75 O November , 100 December. ...........100 " (5) When such annual runoff, so measured, i, equal to or greater than 440.000 acre feet, but is less than 450.000 acre feet, then such releases shall 'be .maintained at the following averaga daily rates of flow. to -wit: DURING THE MONTHS OF: January, ... ............. 1001 second feet: February, 1001 " March. 100,- .............._ — June. ...500 . ................. July . ...................... 501) August . ................500 Septemb:r, ..........400 October, 'SG. " November. .......... 300 " December, 100 ea suc 55555 ru o , so measured. is equal to or greater than 450,000 acre feet, but is less than 500.000 acre feet, then such releases shall be maintained at the following average daily rates of flow, to -wit: DURING THE 'MONTHS OF: January . ..............100 second feet: February,100 ........... March, 100 " April ......... ....... ',lay . ......................400 .. June. 500 July, ......500 August. ...... _........50 0 September, ........500 " October . .............350 November, 200 " December. .. .....100 " (i) When such annual runoff. so measured. is equal to or greater that; :,00,00+) acre feet, but is less than G00,000 acre feet. then such releases shall be maintained at the following average daily rates of flow, to -wit: DURING THE 31ONTHS OF. January . ..............100 second feet: I.,; b' ua ry'. 100 . . ............ . arch, ... -.......... .100 April, ..400 May. ......500 Juste.500 .................... July, ......500 =,t August . ................ � ) September. ........500 October. 400 . .............. November, "00' December. .... 400. (8) When such annual runoff, so measured, is equal to or greater than 600,000 acre feat, but is less than 300,000 acre feet, then such releases sh311 be maintained at the following average rates of flow, to -wit: DURING THE MONTHS OF: Jan-tary, . .............. 400 second feet; February, Marc ................... 200 April . .................... 54i ) June, ....500 Ju Iy. ........... _....... 500 August , ....500 .. .. Septamber. ........500 October, 500 " November. -400 " December . ..........-300 (9) WI; -!n such annual runoff, so measured. is equal to or greater than 800,000 acre feet, then such releases shall be maintained at the following - average daily rates. of flow. to -wit: DURING THE ,MONTHS OF: January . ................500 second feet: February . ............5 00 March. 500 June . ........................ 500 July, ..500 August . ................5 September, ..........500 October ............... November, ..........500 December . 500 " All release schedules provided for in Paragraphs (1) to (9) incl. shall; be minimum schedules, provided, how- ever, that if defendant East Bav Dis- trict elects to exceed said schedules, It shall not by so doing deplete its reservoirs to such an e_(tent as to pr,3- vent compliance with the schedule for the calendar. y-ar in question. (10) If the total annual runoff of the Mokelumne River so measured in any calendar year is equal to or great- er than 450,001) acre feet, but is less than 500,000 acre feet, and if there has trot been discharged over the spillway of and/or through said Pardee dant within ten days prior to July 1st. suf- ficient water to produce a flow In the river at Lancha Plana Gauging Sta• tion in excess of 2,000 second feet con. tinuing for forty-eight hours. then the re:euses shall be so increased as to produce a flow of 2,000 second feet for forty --eight hours. commencing on the 1st day of July: and it a like floc, over the spillway of and/or through said dam has not occurred within ten days prior to august 1st. a like ad- ditional releases shall be made com- niencing oil August 1st. (11) if th-- total annual runoff of the Mokelunine River so measured in any calendar year is equal to or grea. - er than 500,000 acre feet• but is leas than 600.000 acre feet. and it th-2rq has not been discharged over the spillway of and/or through said Par- dee dint within fifteen days prior to May 1st. sufficient water to produce a tww in the river at Lancha Plana Gaugiag Station in excess of 2.000 sec- ond feet continuing for forty-eight hours, then the release shall be so In- creased as to produce a flow of 2.000 second feet for forty�eight hours com- ntencing on the 1st day- of May: and if a like flow over the spillway of anti/or through said dans has not oc- curred within ten days prior to July _ 1st. a like additional release shall be made. c:mmencing on July 1st: and If a like flow over the spillway of and/or through said dam has not oc- curred within ten days prior to Aug- tl`f 1St, a like additional release sfall- be made commencing on August 1st. (14) It the total annual runoff of the Mokelumne Rives so measured in any calendar year Is equal to or great- er than 600,000 acre feet, and if thera has not been discharged over the spillway of and/or through said Par- dee dant within fifteen days prior to April 1st, sufficient water to producp a flow at Lancha Plana Gauging Stz- tkm in excess of 3.000 second feet cos- tinuin; for forty-eight hours. then the releases shalt be so increased as t.,) produce a now of 2,000 second feet for forty -right hours commencing on the 1st day of April; and if a like flow over the spillway of and/or through said dam has not occurred within fifteen days prior to May 1st, a Iike additional release shall be made com- menciae on May 1st; and if a like flow over the epi(Lway of and/or through said dam has not. occurred within ten days prior to July 1st, a like additional release shall be made commencing on July 1st; and it a like flow over the spillway of and/or through said dam has not occurred within ten days prior to august lit, a like additional release shall be made commencing august 1st. (13) Defendant East Bay District shall be released from the obligation to make that portion of any of the flushing. releases provided for in sub- paragraphs (10), (11) and (12) of this paragraph Fifth which is In excess of the regular scheduled average daily release herein provided for the dates thereof if within thirty days prior to the initial date provTdTfor each such flushing release there shall have been discharged over and/or through the Pardee dam sufficient water to pro- duce a flow in the river measured at Lancha Plana Gauging Station of 2.000 second feet for a total of five contin- uous days' duration. Furthermore. de- fendant—Hca., say- District is permit- ted at its option in any ,year to post- pone the flushing release specified for July 1st and August 1st, respectively. until dates not later than July 15th and august 15th. respectively. (14) In order to coordinate pred!,:- table stream flow in each year with the actual stream flow as It develops for that year. the releases cf water required under paragraphs (1) to (13). both inclusive. of paragraph Fifth of this judgment. shall be accomplished in the following manner, viz.: a. The said defendant East Bay District shat. release during the months of January and February of each year a minimtim of 50 second feet daily average f!ow.- and during the month of March of each year a minimum of 140 sec- ond feet daily average flow, sub- jaet to the following provisions: 1. If. at any time during the months of January or February the waters impounded from all In- flow into the East Bay N-funicipal Utility District's 31okelumne Riv- er Reservoirs shall increase by three thousand (3.000) acre feet or more, and the total waters th?n impounded in the aforesaid reser- voirs shall be equal to or exceed one. hundred and forty thousand (140.000) acre feet, the rtinimunt release schedule shall be increas- ed to one hundred (140) cubic feet per second daily average flow for, the remainder of the aforesaid months: providing that at no time shall such increase in the mlui- utum scheduled releases deplete the quantity of water impounded in the aforesaid reservoirs below the quantity that may have been impounded therein on January first of such year, or in no lit - stance to a quantity less than one hundred and thirty-seven thou- sand (137,000) acre feet. E. If, at any time during the months of January. February or March the waters Impounded front all inflow into the East Bay Municipal utility District's Moke- lumne River Reservoirs shall In- crease by nine thousand (9.000) acre feet or more, and the total waters then impounded In the aforesaid reservoirs shall be equal to or exceed one hundred and forty-six thousand (146,000) acre feet, the minimum release sche- dule shall be Increased to two hundred (200) cubic fret per se- oand daily average flow for the remainder of the aforesaid months: providing that at no time shall such Increase in the mini- ntum scheduled releases deplete the quantity- of water impounded in the aforesaid reservoirs below the quantity that may have been impounded therein on January first of such year, or in no in- tance to a quantity less than one hundred and thirty-seven thousand (137.000) acre feet. 3. If, at any time during the months of January, February or March the waters Impounded from all Inflow Into the East Bay Muni- cipal Utility District's Slokelumn? River Reservoirs shallincre-iseby twenty --seven thousand (27,000) acre feet or more. and the total waters then impounded in the afor:said reservoirs shalt be equal to or exceed one hundred and si.%,,,*-fo::r thousand (154.000) acre feet, the minimum release sched- uled shall be increased to five huff -'red (540) cubic feet per se- cond daily average flow for the rent in, er of the aforesaid months: providing that at no time shall such increase in the minimum scheduled releases deplete the quantity of water impounded lit the aforesaid reservoirs below the quantity that may have been im- pounded therein on January first of such year or In no instance t•D a quantity less than one hundred and thirty-seven thousand (137: 000) acre feet. b. Using the same measuring stations as required by paragraph Fourth (4) hereof to be used by the defattdant Pacific Gas and Electric Company for the b,sic measurements upon which its schedule of releases is herein made mandatory, and such data obtained thereat as may be fur• nished to it by said dafendanc Pacific Gas and Electric Company tinder the terms hereof, the de- fendant East Bay District shall determine and estimate as ac. curately as is reasonably possible through competent engineering re- presentatives, from said data and from measurements of the ac- cumulated precipitation of rain and snow- as measured at Wesc Point and Electra and in the vt- cinicy of Blue Lakes as reported by the United States Weather Bu- reau Station for such locality, and front measurements by the United States Geological Surrey of tha flow- of the 3Iokelumue River made at Mokelumne Hill Guaging Station, or its equivalent location, the probable total annual runoff of said stre: m as e3ti: cit- ed out the first day of April cf each successive calender ye.r, and again as estimated on the first day of July of each cale«dar yaar. furnishing copies of said estimates and oiniputatious on which they are based to plaintiff as ra�lll as they are completed: provided, that if after sufficient records have been obtained of preri:31ta- tion measurements at Blue Lakes It should appear that the measur- ed precipitation at some other sta- tion on the Mokalumne River watershed or an adjacent water- shed, or the average precipitat:an of more thaw one station on the Mokelumne River watershed or an adjac=nt watershed bean a de. finite relation to the average of the precipitation at West Point and Blue 'Lakes, than the meas- ured precipitation at such sta:i.jn or stations may ba substituted b; either or I:oth defendants at their options for the measured precipi- tation at West Point and Blue Lakes as a means for determining the respective obligations of the said defendants hereunder. e. The primary releases to be niad3 by said defendant East B-iy District during the months of a.pril. �.Iay and Juni of each year shall be in conformity with the stream flow schedule found in subparagraphs (1) t,:) (13) of paragraph Fifth hereof to be ap- propriate for a year having a total annual runoff within raag:s which include the estimates of rutoff so made. d. The flushing rel:ases here- in required to be ziade each year during the niotiths of April and Mv.y, and, if at ail, shall be based on the schedule found in sub -para- graphs (10) to (13) of paragraph Fifth hereof to be appropriate for a year of annual stream flow with - In ranges which include said esti- mated total runoff prepared as aforesaid on April first of each calendar year. The said flush- ing release to be made comnien- cing on July first and August first. if at all, shall be based on the range of stream flow Including the total annual stream flow as re -estimated on July first of said calendar year. e. After July 1st of each calendar year, the defendant East Bay Dis- trict, having made on said data. a corrected estimate of the total run• off of the Mokelumne River for such year as of said date, shall com- pensate for the difference. if any, b a.tween the releases required by this judgment for the first halt of a runoff year corresponding to tine estimate made on July first and the releases actually made In conformity with said estimate of April first, including scheduled flushing releases, by subtracting from or adding to the sehedule.of releases appropriate for the run. off year as determined by tine July 1st estimate, an amount of water sufficient to ooripaasate for such error in the earlier estimate: pro- vided that such supplemental re - teases or subtractions shall be di• vided as evenly as is reasonably possible over the number of days in the months of July, august. September and October of said year; and provided further, that the total average daily releases required to be made in July. Au- gust, September and October of any year, including compensatory additions, shall not exceed 500 second feet, nor shall compansa- tory subtractions reduce any daily scheduled releases during said months below 450 second feet in any year where the primary schedule herein prescribed for such year specifies a greater re- lease than 450 s:cond feet as au average daily flow. nor below 250 second feet in any year what- ever.- f. hat- ever:f. For the purpose of determining compensating releases in any given year as herein required, the defendant East Bay District may also ignor-2 runoff caused by rain. fall occurring in Xovamber or De. ceniber of such year if such Xo- vrmber and December runoff would require compensation is stream flow releases beyond tl•e amount estimatid on Ju!v ?st. g. The measurements of o?rear• flow- showing the total amount of water flowing in the Mokelur.tne River which is available for stor- age, diversion and release by the defendant East Bay District wa- der the terms of this decree, shall be made at the United States Government gauging station near, 3lokelumno Hill: the measure- ments of waters released from the Pardee reservoir shall be made at the united States Government gauging station at Lancha Plana. a short distance below the Pardee dam. There is no substantial In- crease in the flow of the Moke. lumne River between Lancha Plans Gauging Station and Clzm- ents, and a more accurate record of said releases can be kept at said Lancha Plana Gauging Sta- tion than at the Clements station, and if for any reason either of said measurement stations should be abandoned by the United States Government or the computation of daily discharge therefrom be discontinued. or it the measure- mint- of precipitation at Electra. Blue Lakes and West Point sta- tions should for any reason be discontinued, it is required that in the operations of defendant East Bay District it shall main:aia and operate said stations at said points or at such points as may be sub - situated th--refor under ; e pro- visions of paragraph b. of this section of the Judrmen:. record the measurements of precip(tatiou and stream flow- shown thereat. and shall make the eo=putatsons of daily discharge, all in a manner and with accuracy similzr to that of the United States Government. Said defendant shall furnish and deliver to plaintiff copies of said precipitation and stream flow estimates and measurements for each month and the data on which they are based, within 30 days from the closing day of that month. Sixth: That the defendants East E;ag Municipal ].fluty- District and Pacific Gas and Electric Company, and each of them, their officers. agents and employees, are hereby en- joined from diverting or stcring the waters of the Mokelumne Ricer. ex- cept in substantial conforwity with the terms of this decree. Seventh: That subject to the prior- itles of the plaintiff as he-ein found and to the obligation to measure, store and release water as hereinbe- fore provided, defendant East Bay Municipal Utility District ow•us and Its title is hereby, quieted against plaintiff as to the following water di. version and storage rights, viz.: (a) The right to diver; from said stream at Pardee reservnir trom January 1st to December 31st of each year, 310 cubic feet per second of the flow of the Moke- lumne River. and to convey the same away from said river for municipal and domestic uses, and the right to collect and store for like purposes, in said Pardee res- ervoir, from the 1st day of Octo- ber to the loth day of July next ensuing in each season, 217.000 acre feet of the waters of said river: provided, however. that the combined diversions from the rater flowing In said stream and from storage in said Pardee res- ervoir shall not exceed the equi- valent of 310 cubic feet -of water per second, or approximately "_00.- 000.000 gallons per day. (b) The right to divert from the waters of the Mokelumae River flowing in said stream from January 1 to December 31 of each year, 750 cubic feet of water per second, for the purpose of develop - Ing hydroelectric en?rgy In the power house or power houses to- cated at the base of said Pardee dam, and the right to collect and store iu said Pardee res!rvoir from January 1 to December 31 •)f each year. an additional ?17.000 acre feet of water for such power rise: all water diverted and=_r such appropriation to b± returned to the Mokelumne River at the base of the Pardee dam. (c) The right to store 35.000 acre feet of the waters of said Mokelumne River from Janunry- 1 to December 31 of each year in a reservoir to be constructed and known as the Middle Bar reser• voir. located immediately above said Pardee reservoir. and to di- vert 750 cubic feet of water per second from January i to Decem- ber, 31 of each year, said water to be used for the gere-nation of power at a power house to be lo- cated at the base of said Middle Bar dam, and to be returned to the Mokelumne River and/ur Par. de: Reservoir at the tailrace Lf said power house. Eighth: That the Court hereby re- serves the right and jurisdiction to make such further orders as may be necessary- to carry- out the terms of this de -tree• and to cause the opera- tions of the defendants or their suc- cessors in interest to conform reason- ably therewith. Ninth: That plaintiff recover from defendant East Bay Municipal Utility District 5K,: and from Pacific G 4 and Electric Company 5419, of Its cost, hereia incurred. Done In open court this 14 day of August. 1433. BENJAMIN C. JONES. Supe. -)or Jud.ze. 7. MEMORANDUM OF4 DECISION AND ,has constructed the Pardee' dam an - - BORDER FOR FINOINGS '''a reservoir. Below the dam it has -,:•_.r_.; _ - built a poker house for the genera- This',- actiori enera•This'--action ; Erivolves claims to tion of electrical energy by the use Frights in the maters of the 3lobelumne or nacos discharged through the -dam. river, • a -stream which .has Its source Ttie discharge outlets through the ' near the summit of the Sierra Nevada ' dem and power house have a maxi - mountains 'In axi-mountains'in California. -and flows muss capacity of approximately'., 50 _ -westerly to a confluence with the San second feet. On the south side of the -_Joaquin .and Sacramento rivers at a river at this point the East Bay •D!s point near where these stream_ s join. tract has. constructed a -diverting tun- - _ �,•'-r along -.'the upper reaches 'of the nel to connect with its pipe lines l:ad• _ giver the 'defendant Pacific Gas and in; to Oakland, which tuanel has a Electric company has been operating max -mum diversion capacity of •350-- a system of hydro electric properties second feet. , over a period of time running back a Further to the nest, and near the great many years. with the attendant town of Clements, the rive: debauches,:-'- Impounding and diverting works b. from the foot hills and flows is a gen= _- - which a portion of the flow of the era! westerly direction past the towns stream has been impounded and di- of Leckeford, Lodi and Z400dbr1d,e: versed and used in the generation of Its course from Clements is through • electric power. _ bottom lands which are bounded b P.' G. 1. E. CONSTRUCTION _ ter -_aces of slight elevation. These ;-7 More recently this defendant has terraces merge into the .surToun�in,' - constructed Its Salt Spriggs rose oir plains at a point on the river opposite. With its Empoundiag dam and dice t• Lodi. From Clements to � oodbrdge' _ 'ing-canals; and has taken certain pre- the river chancel is approximately 1-00 liminary-•steps requisite to- the • con- feet wide at tue bottom and "200`feet`_''','.�f _-.struction of additional reservoir fa• -wlde at the top. '.Through this po:pion ciEities.on Bear Creek, and at its lows, of its course it will carry's no of s-Deer:Z'_all?y reservoir site.' -By means about 2000 second feet without o -e: for itsdiverting Rork the defendant -flowing the adjacent bottom 'lands:� _`. Pacific" Gas ':and Electric compaay_~:' WOOD8REOGE IRRIGATlO h:z�`; conveys, and proposes to convey, a - ` A• Woodbridge a diversion dam has •--r d r portioa''of the flow of the river to a been constructed by the �ioodbridge _,• point-above'Electra where tbe'witer l-, igation District, and a portion of__Tr_;= 'e :dropped through penstocks .to t_'ee the water oC the ever is -diverted f_'��power=house�aad released through the the south through an irrigation ditch*- i =� hich supplies ater-to •a_. Cons id _;__�-:�;•r•,.;tatlraee=intq'the=Hain channel__oL�tSe--wuw -. _ - _ _., ,. _ _• �=_-;,:, atream,r`The activities -i the defend --able -area = sonthiyesyer�IF ` of �Lood Gas and:Eiectric'company=brdgeand Lodi.'West'ofFCoodbrd3e;—�;;;=, sv_-;are confined -solely to.the•north._fork.-aa the '.river `rLhB^d21t3 `��,y .the' Mokelumne river. lands Its Mall is ver..._slt w-� Fes= .Below -the.Electra:power:house the-.4Dry, _.north^fork'of the:stream_unites with' Creek flows in'a-general ;-;the muddle ,fork.and the -south fork to =rection -and-parallel •to'<the •-I,keinm _ -<form'the main body of the 3fokelumne . ne river.; Its course; '•howe -er,-is at an a*ati_ -river: = _: �, c _:' =- -.::�approxima_te;aievatlon,ot�4000: feet as,-s��_ SAY HOLDINGS ' ~�contrasted'..to:10,000-Leet�ot. theIfo- t .a tpoint .-on the river -create:lp,.+eiumne -with _ a consequentscontribu --„r ;-�fokelumae • Htll .and above �tioa tofits runoff ot-but'.little _ivater- _ I.an ha lana h.Bay.• y defendant'East �'ironi`-melting'=snoRs:�South''=o:the -^rjY ��tunicipal TJtility District. -here [na r `�f eoSelumne'-is'. another =st-eam :caked �OQ ==" —:reLerred'tq_a� the a te$ap-District.-Bear _.Crefa,' R_hich has .its "source` az-..:- W z—.. •C �'S �-•'--._? :cam-�� � �-- __ - -- - —`_ .T--•�-r y = - _ _ �"'t�� n- the foot hills and which also flows in. an'area'from three to four miles wide - a'general westerly direction. The - and extending southwesterly from the course of Bear Creek is relatively river a much higher percentage of short and its flows are limited to water bearing material is encountered storm freshets. as is, evidenced by the logs of var- CITES RESERVOIRS "" `ious wells in that vicinity produced - Above .the Pardee Reservoir is an- by different land owners. The opin- other reservoir known as the 3Iiddle ions of the geologists are somewhat - Bar site with a storage capacity of in conflict as to the existence of an approximately 25,000 acre feet," and alluvial cone in the area referred -to, for the use of which the defendant although they agree that the soil de. East Bay District hay filed its appli- posits are alluvial In character. In cation with the Stats Water Division. any event, the area to a considerable Below the Pardee Dam and above distance both north and south of the Clements is a second reservoir site ylokelumne, and westerly from Clem - commonly known as the Mehrton site, encs, and to a considerable depth, can - ane which has a potential storage ca- sists of alluvial deposits of varying _- pacity of several thousand acre feet. degrees of porosity, and in which Is Other than the application of the Ezst found an abundant water supply. Bay District to utilize the Middle Bar WELLS MENTIONED site. nothing of any consequence has . The City of Lodi is situate on this been done hi the development of alluvial plain, which, as before stat - either of those sites for storage. ed, extends for a considerable dis- The Mokelumne in its upper reaches tante In all directions from Lodi, and flow's generally in a deep and broad across which the 'iokelumne river canyon, eroded in the granldc forma* flows. The City of Lodi has sunk tions of the Surras, and runs thence walls at a point about one and one- across the newer volcanics and the half miles sourhtrly from the Moke- lone formation to a point about where lumne river and extracts from the it Is crossed by the range line be- water bearing strata a considerable tween Ranges 3 and 9 East. 3i_ D. til., quantity of water which it supplies .where its grade diminishes percep• to its inhabitants for domestic . and _ tibly. At this point the toot hills also household uses. These wells are sit - begin to recede. uate on parcels of land Domed by the GEOLOGISTS DIFFER City of Lodi and within its city Loa - There is some difference . in the its. The elevation of the surface of geological opinion as to the manner the ground at this point is about 50 In which the soil strata to the west of feet above sea level, and the general this point were laid down, but in the surface of the underlying water table main the geologists are agreed upon is approximately 25 feet lower. -.the' character of the soil structure, The United States Department of . and that to a considerable depth It the Interior through the United States consists of depositions by stream Geological Survey has made an ex- = flows of varying degrees of porosity. tensive study of the underground '* Dr. Tatman•s computation based upon water situation in and about Lodi, - -: the logs of wells of varying depth and has incorporater In Water Supply an average of loco of the soil Paper 619 a vast mount of the data strata as water bearing material. This collected. . This bulletir_ has been in- = = _a�erage includes Welts is the vicinity troduced is evidence and is the basis_ - =of Dry Creek and Bear Creek, and of much of the expert testimony of- :`wells locatedin • the - comparatively fered. ght tilehrton formation. .-. •'., - WATER DECREASES _. Taking w-eIls'- in . the -immediate.' • In the area under consideration by - - - vicinity of Lodi, and particularly in --the engineers of the Geological Sur- vey; which area extends from Bear sionaliy reaches a flood stage at other Creek on the south to Dry Creek on times In periods of exceedingly heavy the north, the water table has been rainfall, but such floods are infre- steadily dropping since 1907. Of this quest and occasional. area there are in excess of 34,000 STORAGE CAPACITIES acres is the immediate vicinity of The works of the defendant Pacific Lodi where the ground water is direct- Gas and Electric Company on the ly affected by percolation from the north fork of the river provide a stor- blokelumne River. (East Bay Ex- age capacity of approximately 1S5,000 habit 102.) To the west of this area acre feet. done of the water fir - are the ]ands Irrigated from the pounded and diverted by this defend - Woodbridge canals. ant is taken from the watershed of There are about 70,000 acres in the the 31okelumne, except a small area lying between Dry Creek on the amount which is supplied to- the north and Bear Creek on the south. cities of Jackson and Sutter Creek In all about 2,000 wells tap the under- under an old appropriation.. The ground waters in this area and de- Pardee Reservoir of the defendant liver large quantities of water for do- East Bay District has an approximate mestic and irrigation uses on the sur- storage capacity of 220,000 acre feet. face of the land. Nearly all of these The diversion tunnels of the East wells are located in the area In and Bay District, with a maximum capa- around Lodi, which is hereinafter re- city of 310 second feet cunstant flow. (erred to as the Lodi area. The Fed- are capable of diverting 200.000,000 eral Government maintains gauging gallons of water daily, or 224,000 acre stations on the river at Woodbridge. feet annually. There is also an addi- Clements and 3lokelumne Hill. Other tional loss of 4.000 acre feet annually stations are also maintained at other by evaporation from the surface of points on the river and in the water- the reservoir. At the present time shed for the purposes of measuring the district is diverting approximately the runoff of the river and the snow $0,000,000 gallons of water per day, and rain fall. or about 90,000 acre feet per annum. RUNOFF RECORDS OAKLAND RESERVOIRS Since the season of 1906-07 a record The district has reserve storage has been kept by the United States facilities in the vicinity of Oakland Geological Survey of the runoff of with capacities sufficient to meet all the `lokelumne River, in which year of its present needs for a period of the maximum seasonal runoff was six months ^ :thout replenishment. 1,670.000 acre feet. In the -season of Approximately 3,600 acre feet with a 1933.24 the runoff amounted to only maximum rate of 22.4 second feet is 132,000 acre feet. Seasonal runoff Is the annual draft of the City of Lodi measured beginning October 1st and from the underground strata. - Alto - extending to September 30th of the gether there is an annual draft o1 following year. The average seasonal about 30.000 acre feet upon the under - runoff Is approximately 300,000 acre ground strata for irrigation and -do-_ - feet. The runoff measured according mestic uses in the Lodi area. to the calendar year is somewhat -- In the entire area between- Bear higher than the seasonal runoff. _ Creek and Dry Creek the annual The maximum Slow of the river draft on the underground supply usually occurs in the late spring or approximately 70,000 acre feet- The early. summer when the melting diverting canals of the Woodbridge snows In the Sierras augment the Irrigation District have a . maximum =.- flow- of the stream. These annually -capaclty of 250 second feet and the recurring high flows constitute a part district Is now diverting from 'the of the normal flow. The river occa- river about 6565,000 acre feet for use' .� (3) COURT POWERS BROAD these circumstances it cannot be said No matter. what may be the com- that any portion of the right to permits by the State Water Commis- been admitted by the plaintiff, ex- sloa.and the Federal Potter Commis- cept as to the right to divert a 75 sec- sion for the appropriation of certain and foot flow of water outsida of t:ie waters of the Mokelumne, and makes watershed of the 5fokelumne to the these permits the, basis of its claim cities of Jackson and Sutter Creek, of title. although the right to so divert 30 sec• It has been held iq the case of and feet is conceded. - i Yuba River Power Co. vs. Nevada EARLY APPROPRIATION Irrigation District, 207 Cal. 521, that It has been stipulated, however, that an action in equity in the nature of the appropriation under which the 75 a suit to quiet title may be maintained second foot flow is claimed was in - by the holder of permits from the itiated in early days, and actual diver- - State Commission to determine ad- sion made. upon lands which were verse claims to the use of water by then unoccupied and which belonged other claimants. While the plea of to the United States Government. ownership and adverse claim is set There is no claim that this right was up by nay of answer, a court of ever abandoned. The only point made equity, nevertheless, takes jurisdic. is that the place of use as to 45 sec - Lion, and ]caving assumed jurisdiction and feet of this appropriation has of the subject matter and the parties been changed from Jackson and Sut- Will proceed, to the end of preventing ter Creek, which are outside of the a multiplicity of suits, to dispose of Mokelumne watershed, to the Electra all the equities and priorities exist- Power House, which is within the Ing between the parties. watershed of the 3lokelumne. finder COURT POWERS BROAD these circumstances it cannot be said No matter. what may be the com- that any portion of the right to plications or complexities, the powers divert 75 cubic feet per second of the of a court of equity are so broad as water of the Mokelumne has been to adequately meet the exigencies of lost - the case, and it may so mold its de- - Smith vs. Hawkins, 110 Cal. 129. tree, and may determine the ultimate Rood vs. Etiwanda Water Co., 122 rights of the parties on either side Cal. 152.. as between themselves or the oppo- South Yuba Water Co. vs. Rosa, 80 - site party and docree_ accordingly. Cal. 333. _ Collier vs. Merced Irrigation Dist., With the exception of its original 213 Cal, 554. appropriation of 75 second feet for , ' Wenban-=•E§tate, Inc.,..vs. Hewlett, ` diversion to Jackson - and Sutter -_19.3_--Cal;.?b75.' - _ - Creek, the defendant Pacific Gas and _ Califo_ rnhi - etc-, Co. vs. - Schiappa- Electric Company contends that in Pietra, 191 Cal. 732-T44. - - . ` " ' _ the operation of its entire system of ' • " _.= Arthur vs. Graham, 64 Cala App. works it is exercising only its rights _ 60ii 612. '-i : ... as a riparian owner - on the stream, The . defendant ' Pacific Gas and and that its operations are only_ in Electric Company, after denying dam the exercise -of riparian rights.. " - age to the plaintiff, has alleged its -- = NOT RIPARIAN RIGHT `-, ov ne_ rship for more than twenty years - However, has been `repeatedly "_ -" -r;"of a system oi'reservoirs, ditches and ,'it held in this stat?" that the' storage of canals, tights 'of way and divers.par- w=ater -la one=season for -use - = cels of riparian Nand, together with other is not an act in pursuance o1 a t.�,...4_.r• rights- to: the =use of waters -of the-riparian.right,.but is an act. adversei-.-2'-r _,;4 north fork of the blokelumne River to riparian owners below. " _ (Seneca:: and its -tributaries in the operation of Consolidated Gold -fining Co. vs. The - this older portion of -its system, which Great - Western Power Co., "209 Cal. ownership_ by the said defendant has -206.) _The defendant Pacific Gas - -•`7; _. =:.:`�:�: --- _- --_-_- -_: _- r-.. --_•_ _'' __ 'moi and Electric Company has, therefore, As to the effect of such operations In all of its operations been exercu- upon riparian rights below, it may be ink appropriate rights in the waters noted that in actions to recover dam - of the river. The rights to the use ages for the invasion of such rights of the Nvater which it has acquired by reason of such -upper storage, rip - in connection with the operation of its avian owners in this State are lim- ;+ older system of works, together with ited to the difference in the value = the 75 second foot appropriation or- of the riparian lands under the na- iginally made for diversion to Sut- tural Clow of the stream, and the ter Creek and Jackson, are, however, value of the lands with the flow as paramount to any right of the plain- modified by the construction and oper- tiff. ation of the impounding and divert - The defendant Pacific Gas and ELec- ing works. tric Company further alleges in its Seneca A. G• 11. Co. vs. Great West - answer an abandonment of a16 waters err, Power Co., 209 Cal. 206-222. returned t6 the main channel of the Collier vs. Merced Irrigation Dist.. Mokelumne below its Electra power 213 Cal, 554. house. This includes the water di- CITES COLLIER CASE verted through its older system of This holding is based upon the works as well as_ that held in its Salt theory that while the riparian right Springs reservoir. All of this water Is a part and parcel of the land, it _ so returned to the channel at Electra Is nevertheless a_usufructary one in has its origin in the stream. None the flow of the stream, and that the of it in the process of its' use is ever resulting difference in availability of carried out of the watershed of the water for use is the damage.' As was 1Iokelumne. and the returned flow is said in the Collier case, supra: "Any in no way increased by any water Injury short of a complete divestiture brought -in from a source other than of the right leaves a quantum in kind the ltokelumne or its tributaries. The in the proprietor thereof. If the in - water which is returned at Electra truder relinquished a part of the right is exclusively water which has been to the channel of the stream to that impounded and diverted at higher extent he restored the right to its = elevations on the stream. rightful owner." WATER DELAYED Measured according to the amount _ of damages recoderable, the loss sus - It is the same water which would tained by a lower riparian owner by flow in the same channel under na- the impo:inding and diversion above tural conditions and in the same on the stream is the difference fn quantity and of the same quality. By flow under natural conditions and the _ the operations of the defendant it has .flow as modified by the operations merely been delayed in reaching any above. - given point on the stream below. The The factors contributing to the precise question presented is as to change in flow in this case are the whether in the operation of impound- Impounding and diversion of the a , ' ing, diverting and returning to the waters- Of these two factors the im- natural channel waters of the stream pounding contributes in the greatest _ an impairment of a right below has degree to the change in the time been effected to the extent of the full when the water reaches any given .•. amount of the Rater so diverted and point on the stream below. Assume =- - -- returned, or only to the extent of the a situation on the stream where a .: difference between the flow of the dam, or a series of a -few dams have _ stream under natural conditions and been constructed, and which are only - the flow as modified by the opera- slightly closed so that the water will ;t tions of the defendant. flow past with only a slight retarda-'. (6} tion at each point of observation. by "cutting across, so that water com- Could it then be said that the flow ing into the channel would reach a Of the stream has been so changed as given potat below in one half the to make it foreign water? time that it would under the former Assume the number of dams to be conditions, would such a change in increased and the discharge capa- time change the flow into foreign r cities reduced until the flow of the water? ` stream is regulated to an exactly SEEPAGE NATURAL FLOW even flow over a season of run off, In other jurisdictions, notably in would the resulting effect in the Massachusetts, Rhode Island and character of the water be any differ. Colorado, it has been held that waters ent? Assume the cumulative effect which have been impounded or divert- uf such dams to be exactly equal to ed and later returned to the natural that of the impounding works of the channel form a part of the natural Pacific G4s and Electric Company in flow of the stream. Similarly, in Cal - this case, and does the conclusion fol- ifornla it has been held that seepage low that the effect of the impound- from a diverting ditch finding its way ing is to change the water to foreign back into the natural channel be - water? comes a part cf the natural flow of CANAL DIVERSION the stream. (Southern California In - The effect of the diversion canals vestment Company vs. Wilshire, et upon the flow of the stream depends at., 144 Cal. 65.) largely upon the length of the canals upon principle and authority it between the points of diversion and must be concluded that the waters return, the grade, and the freedom of of the Mokelumne stored by the de- flow- therein. If a greater time is re- fendant Pacific Gas and Electric quired for the water to flow through Company, and released into the chan- the canals between the points of di- net of the river, constitutes a part version and return, the effect would of the natural flow of the stream, and be cumulative to the impounding. If are subject to the rights of lower less time is required, the effect would riparian owners, appropriators and be compensating.. others having vested rights in the In the latter case it would require waters thereof. less time for the water to flow LODI'S PRESCRIPTIVE RIGHT through diverting canals than in the. The City of Lodi operates its wells. natural channel owing to a shortened and disposes of the water from the distance and a greater freedom of same through its distributing system flow due to lack of natural obstacles. by virtue of a prescriptive right The effect would be analogous to that which it has acquired by adversely obtained by removal of obstructions extracting water sufficient for its re- in the natural channel, or by straight- quirements from the strata underly - ening out the same. In either case ing.the city and surrounding territory the Nater would arrive at a point on for many years. All the elements _ the stream below earlier in time than essential to the establishment of a it would arrive under natural condi- prescriptive tide have been involved tions. Also, it is entirely conceivable in its use of these waters. (Silva that such a modification in the Ha-wm, 10 C31. App. 554-551.) _ natural flow of the stream would be The title which Lodi holds to this Injurious to lower riparian owners. ,right has its origin, in this. prescrip If the natural channel of a river were. Live use and not iu any appropriation to be so altered by removal of all ab- as it is ordinarily .understood.' ,As. • _ i structions, such as rocks, trees, over- was said in San Bernardino vs. River- hanging brush, drifts and the like, side, 186 Cal. 7-13: "Appropriation -mow and all bends and turns eliminated ... is but another form of prescrip- c7) tion." With reference to a prescrip- tive title the lacy conclusively pre- sumes an antecedent grant by an in- dividual to the holder of such a pre- scriptive title or right. (Smith vs. Hawkins, 110 Cal. 124.146; Hildreth vs. Montecito Creek W. Co., 139 Cal. 49.) HOLDS GRANTEE POSITION as the City of Lodi, by virtue of its prescriptive right, occupies the po34- tion of a grantee of all of the owners of lands overlying the water bearing strata of the Lodi area, any vested right of any such lard owner in the -.caters of the Mokewrane River pass- ed to the City of Lodi according to its appropriation. The rights of such overlying land owners as between themselves as defined in Hudson vs. Daily, J56 Cal. 617.645, as follows: "Tae general rule, as now estab- lished by the decisions of this court, undoubtedly is that where two or more persons own different tracts of land, underlain by porous tnaterial ex - to and communicating with them all, tvhich is saturated with water moving with more or less free - dont therein, each has a common aad correlative right to the use of this water upon his land. to the full ex- tent of his ae-_ds if the common sup- ply is sufficient. and to the extent of a rea;onable share thereof if the sup- ply- is so scant that the use by one will affect the supply of the others. (Katz v. Walkinshaw, 111 Cal_ 134, 144. 150 (?.m. St. Hep. 35, 70 PRC. 9j.', 74 Pac. 766); McClintock v. Hud- son, 1.11 Cal. 4S1 (74 Pac. 3.49); Cohen v. La Cenada, etc., Co., 114 Cal. 439 (76 Pac. 47); 'Montecito. etc.. Co. v. Santa Barbara, 144 Cal. 5S5 (77 Pac. 1113): Purr v, 'Maclay, etc., Co., 154 Cal. 4:334 (93 Pac. 460); Bartoa v. R)v- erside Rater Co., lbs Cal. 509 (101 Pac. 7903)." APPROPRIATOR RIGHTS Tae rtghts of two appropriators from a basin are defined in San Bernardino vs. River side, 1a6 Cal. 7, v:hera two appropriators, exercising prescriptive rights, were extracting •:-ate.- from a basin in which basin thsre existed a surplus of water, and where neither appropriator in the ex- ercise of its rights was in any nay interfering with the use of water by the other, and where there had been no adjudication in the trial court of any priorities In either of the parties with respect to its water right, as fol- lows: "While the surplus continues, the condition of the respective parties as to their right to take water from the basin for public use is substantially the satr.e as that of several appro- priators from a surface stream having more than enough water for all. No Injunction should issue against the taking of water while the supply is ample for all. But the respective priorities of each water right should be adjudged. so that if in the future the supply falls below the quantity necessary for all, he who has the prior right may have his preferred right protected." It has thus been held that as be- tween two appropriators he who has the prior appropriative right in the waters of an underground basin may have that right protected as against a subsequent appropriator when the supply- of water in that basin falls be- low t -!:e quantity- necessary for all. CITES "INTRUDER" CASE Furthermore. it has been held in the case of Miller vs. Bay Cities Water Co., 157 Cal. 456479, that one who intrudes upon the stream or other source supplying water to un- dergruund strata occupies a' position no different from that of an appro- priator from such strata and is gov- erned overned by the law applying to the lat- ter, the court stating: "It would present an anomalous condition of the law were it the rule that while a riparian owner may pre- vent an appropriator from diverting to his injury the waters of the stream for use beyond the watershed and one owner of land overlying a common stratum of percolating water may re- straia another owner similarly sit - (8) _ uated_lrom making a like diversion, the 'owner of lands whose underlying stratum of water is directly and clear- ly supplied by percolation from the waters. of the stream. and who will be greatly injured by a diversion is not entitled. to prevent it. There is no reason or any difference in the rule between the classes and none should exist. Such landowner has a right to restrain a diversion . from the stream or saturated plane or other well-defined supply, by an appropria- tor or any one else who seeks to divert such stream or other supply- ing waters from their natural perco- lating flow, for use elsewhere than upon lands to which, as waters of the stream, they are riparian, or which, as waters o1 an underground stratum, may reasonably and usefully be applied to the overlying land." In such a case where there is no surplus of water, . and the common supply is not sufficient, and the an- nual average replenishment to the basin is not greater than the demand for reasonable uses by the overlying .land owners, an appropriator from the 'basin, whose rights have ripened, un- doubtedly has the right to enjoin an intruder into the basin, or upon the source of supply, from extracting -water therefrom for use on distant lands, even though such appropriator would have the right to take the full measure of his appropriation as against the owners of lands overlying the basin to the extent of exhausting all the water available. . rights. Any further demands upon.:,.=--._ 11 the supply of underground water . would tend to dimfaish the supply available for overlying Iand owners and appropriators alike and with �I common and Immediate effect. Such additional withdrawals from , the underground strata would cut in- to the residual supply, and, if con- tinued, would bring about a progres- sive lowering of the water table until _ the underground supply would be j completely exhausted. With the pro- gressive lowering of the residual waters appropriator. and overlying land owner would be put to the com- mon necessity of installing more pow- 4 erful pumps to raise his share of the water to the surface. An appropria- tor under such circumstances, with an Immediate injury to his right, is entitled to an immediate remedy, along with the overlying land owner, = to 'prevent an encroachment upon the residual supply, and Is not obliged to wait until the residual waters of the basin have been so far depleted -I that there no longer remains therein a quantity sufficient to meet _ the = 1 amount of his appropriation. The in- jury produced is common and alike = to appropriator and overlying land . , - owner, and each is entitled to the same remedy. whicb, in the case of _ an overlying land owner, has been • ; _ •- - held to be immediate relief. - Katz vs. Walkinshaw. 141 Cal. 134. - Burr vs. 'Maclay etc- Co., 154 Cal. ?.- 434. RIGHT TO PERCOLATION r APPROPRIATIONS ANALOGOUS from an under- The right of the City of Lodi here, - - �_.: : Appropriationsr r. - where the average annual replenish-' ground basin of water are analogous ment through the underground strata .lto appropriations from _a surface under natural conditions Is not.in ex- «': •_: stream with sufficient water. for all cess of the requirements for reason- only When the. average annual re- able uses and purposes. upon. the over-'.-,.,-. plenisbment to the basin is in excess lying lands of the basin, is to have' i= the legitimate demands upon the the residual supply , is _thea. under- -of - - -.and the analogy -ceases when _ground strata maintained .a9 near_ as ;^� ;,•,`;.�.. - :the common- mu ommon supply or recharge be-- may be by the continued -percolation .ins comes _insufficient to meet 'the de `of as much water -into the area from t . <_ -- . 44t _ mands of the overlying land owners the 'Mokelumue River as would occur and appropriators with -established under natural -conditions. This right of the City of Lodi has not been lost by laches, and neither is the city estopped to assert Its right against the East Bay District. The permits obtained by the East Bay District from the State Water Com- mission and the Federal Power Com- mission, were issued to it upon the representation that sufficient water would be released by the East Bay District to meet the requirements of all vested rights ou the stream below-. The permits by their very terms make all appropriations thereunder subject to the vested rights of all persons owning an interest in the waters of the 31okelumne. LODI RIGHTS RECOGNIZED The City of Lodi was entitled to as- sume that the defendant East Bay District, notwithstanding what repre- sentations may, have been made with reference to problematical future needs for the waters of the Moke- lumae based on territorial expansion and population growth, or the maxi- mum capacity of its diverting works, would let down enough water through its Pardee Dam with its 7.0 second foot discharge capacity, to meet the requirements of Its right. almost frons the re:y inception of the East Bay District's undertakiag the extent and character of the plaintiff's right was disputed by It. This controversy between the par- ties was carried on at public hear- ings and in more or less private meet- ings between the representatives of the district and the city. As soon as It reasonably appeared to the plaintiff that the differences between itself and the East Bay District as to the extent of its right could not be set- tled between them this action was be- gun. Where, as here, there has been a dispute between the parties as to the amount of water which should be released to meet the requirements of plaintiff's right, the defendant being in a position to meet these require- ments, it cannot be said that plaintiff has been guilty of laches, or is estopped by failing to file its com- plaint until it became reasonably ap- parent that the differences between the parties could not be settled, and that there would not be sufficient water let down to meet the require- ments of plaintiff's right. The major portion of the evidence in the case is directed to the amount of water percolating from the Moke- lumne River into the Lodi area, both under natural conditions and under the flow- of the stream as regulated by the operations of the defendants. The defendant Pacific Gas and Elec- tric Company has set up in its an- swer a schedule of operations and releases to whlcb it agrees to be bound by judgment, and which it claims ;-ill not diminish the amount of water which would normally per- colate from the Mokelumne River in- to the Lodi area under natural con- dlUon4. Similarly, the defendant East Bay District. by a proferred stipulation read lnto the record and filed in the case during the progress of the trial, has set up a schedule of operations and releases which it claims will not diminish the amount of percolation into the area occurring under natural conditions. The release proposed by the Pacific Gas and Electric Company is a constant flow- of 500 second feet with provisions for a diminution therein in seasons of fight rain fall and river runoff. The East Bay Dis- trict's stipulation provieest for a vary- ing volume cf water to be discharged through its dam, based upon various stages of river runoff and flow-. PRESUPPOSE PERCOLATION Both of these stipulations presup- pose, and it conclusively appears from the evidence, that there is a lar.ge amount of water percolating from the river Into the Lodi area each year. The engineering witnesses produced b, the respective parties are in ac- cord upon the fac! that the greatest rate of percolation from the river oc- curs when it is between the stages of flow- of 400 second feet and 600 sec- ond feet. And they also agree that (10) the higher the temperatures of she water, the greater is the rate of per- colation. Also, that the slope of the water table away from the river is greatest during the irrigation season when the pumpit:g draft is at its high- est and the draw down in the wells the greatest. In addition, Professor Etcheverry, an eminent hydraulic engineer pro- duced I)y the plaf, itfff. testified that under a regulated flow of the stream such as will occur under the releases proposed by the Pacific Gas and Elec- tric Company, there will be no de- crease in the percolation into Che area, but that the same will probably be slightly increased. With the de- feadant Pacific Gas and Electric Com- pany, presumably acting with the re- sults -of the studies of its engineering staff before it, aid the principal en- gineering witness for the plaintiff in accord on ,.hi: fart, it may fairly' be concluded that a flow of the stream regulated by a constant discharge of 500 second feet at the Electra Power House, with corresponding diminu- tions in the flow according to seasons of light runoff and rain fall, is neces- sary to maintain a percolation into the Lodl area such as would occur under normal conditions of natural flow. EXPLAINS RUN-OFFS The operations of the Pacific Gas and Electric Company are confined solely to the north fork of the river, and in no way affect the high flows originating in the south and middle forks. In seasons w-hea the runoff. measured below- the junction of the north. south and middle forks, is one- half of normal, the total amount of water imp,mnaed by the Pacific Gas and Electric Company is less than ore -half of such ru^off. In such sea- sons of comparatively light runoff under the Pacific Gas and Electric Company plan of operations, there will occur in a large measure the usual seasonal high flows in the late spring and summer. It is these high flows occurring when the runoff of the river is down to one-half of normal, or less, that the operations of the East Bay Dis- trict wipe out. It is these high flows occurring late in the year, which the East Bay District impounds, and which by reason of their volume com- bined With the extended lesser flows in the summer and autumn resuting from the Pacific Gas and Electric Company releases that maintain a quantity of percolation into the Lodi area equivalent to that occurring un- der natural conditions. FLOW PRESSURE IMPORTANT The pressure exerted by these high flows is a considerable factor in de- temiiaiug the amount of water per- colating through the lands and grav- els in the bed and banks of the stream into the underground strata. This pressure, or hydraulic head, was considered a very important cause of percolation in the case of Miller vs. Bay Cities Water Co., supra. Also, such flows have an important scour- ing effect upon the channel. Under the natural conditions exist- ing before either defendant came up. on the stream there was a point be- yond which an increase fn the volume of the flow became of less importance in so far as such increase affected Percolation. and also a point in time beyond which a flow- of any conse- quence would not occur. under ex- isting conditions there is a point in volume above which the amount of water running to waste can in no way be equitably balanced against any resulting benefit by way of per- colation. In order to make a more complete utilization of the waters of the river and r -educe unnecessary waste and still maintain the approii- mate natural amount of percolation the high flows should be diminished, and the time of the lesser flows ex- tended. Even in the exceedingly dry years under natural conditions there would be a portion of the runoff con- . tributing little to percolation- (.11) ercolation. HIGH FLOWS CAUGHT With the East Bay District operat- ing on the stream all of the spring and summer high flows are caught and held up to a runoff of 400,000 acre fee t, its reservoir holding 220,000 acre feet .and those of the Pacific Gas and Electric Company 135,000 acre feet, and all late high flows con- siderably modified in all seasons of runoff over 400,000 acre feet and up to the average of 300,000 acre feet runoff. With all of the high flows eliminated when the runoff is 400,000 acre feet or less, and modified in varying degre!s in all seasons of run- off in excess of 400.000 acre feet, a comparatively high and uniform rate of oercoiatioa must be maintained to approximate natural conditions when a deficiency in one, or even two suc- ceeding years, would be supplied by the late spring and summer floods of the following years. Under the operations of the East Bay District the effects of these com- pensating years are nullified, and the releases as proposed for the years of light runrff are not sufficient to maintain 'a percolation equivalent to the natural supply of water into the Lodi area. As pointed out, the oper. tions or the ]lost Bay District allow no room for recovery from the de- ficiencies of the dry seasons, except in the very xet years. To approxl- mate natural conditions the average annual percolation from the river into the area, must be maintained at as nearly a uniform rate as possible. The amount of this percolation has been variously testified to as from something in excess of 10,000 acre feet to something In excess of 30,000 acre feet. i careful analysis of the evidence leads to the conclusion that the latter figure is approximately correct. The releases Droposed by tae East Bay District will not pro- vide any such amount of percolation in the years of light runoff, and the effect of the District's operations will be to cause a progressive decline in the crater table in the Lodi area to the extent of something more than one foot per year on the average. STORAGE INCREASES RUNOFFS Applying the Pacific Gas and Elec• trio Company schedule of operations to the recorded runoff of the river by calendar years, whea the runoff does not exceed 400,000 acre feet. an Increase, on the average, is found over what actually occurred under natural conditions. The average run• off of the three flows under 400,000 acre feet occurring under natural conditions amounts to 234,997 acre feet, crhile the average runoff under Pacific Gas and Electric Company regulations amounts to 463,344, or an average increase of 10,000 acre feet. Similarly. with the five runoffs oc- curring between 400,000 acre feet and 340,000 acre feet, the average under natural conditions is 424.400 acre feet, and under the Pacific Gas and Elec- tric Company regulation 447,470 acre feet, or an average increase of 33,000 acre feet. Obviously, the increases are brought about by the release of waters from storage. The East Bay District comes on the stream with the natural flow aug- mented to the extent of 10.000 acre feet or the average when the runoff under natural conditions would be less than 440,000 acre feet, and aug- mented to the extent of 23,000 acre feet on the average when the runoff under natural conditions would be be- tween 400,000 acre feet and 300.000 acre feet. Taking the stream in -this condition of augmented flow. and ap- plying the East Bay releases to these runoffs of Iess than 400,000 acre feet the result is an average ruaoff of S3,713 acre feet, or an average de- crease of 164,231 under what would have been the runoff without the Pacific Gas and Electric Company Ott the stream, and an average decrease of 174.607 acre feet under the flocs with the Pacific Gas and Electric Company making its releases. Sim- ilarly, with the five runoffs between 400,000 acre feet and 300,000 acre feet, the average runoff under the op- erations or the East Bay District is 227.464 acre feet. or an average de- crease below natural conditions of 196,96 acre feet, and an average de- crease in the flow as augmeated by the Pacific Gas and Electric Com- pany releases of 220,000 acre feet. (Runoff figures from East Bay Ex- hibit No. 19.) PERCOLATION LOWER If the percolation factor produced by Mr. Bonner, called as a witness for the East Bay District, is applied to the various flow. of the river under natural conditions, and under the combined regulation of both defend- ants, the result shows a percolation Into the Lodi area below that which would have occurred with neither de- fendant on the stream, and the great- est proportional decrease in the dry years. Much further discussion might be had with reference to the testimony of the many witnesses called, and particularly with reference to the views of the different experts per- taining to the quantities of water reaching the water table from the rainfall on the surface of the area and front other sources, but as these matters have been carefully consid- ered, such discussion of them here would serve no useful purpose. Like- wise any ext=nded comment on the contention of counsel for the East Bay- District that the City of Lodt should change its mode of operations to meet changed conditions is un- necessary. The nature of the right with which Lodi is casted and the remedy available to it to prevent an infringement of that right renders in- applicable to the present situation the authorities which counsel have cited as being in support of their conten- tions. Judgment herein should be for the plaintiff. and the decree to be pre- pared should provide that the de- fendant Pacific Gas and Electric Com- pany maintain the schedule of oper- adons and releases proposed in its answer, and that the defendant East Bay District release through its re- tainlag dam or dams down stream when the runoff of the lrokeiumne River is Iess than 250,000 acre feet Irk any one calendar year, measured by the united States Geological Sur• vey at the intake of defendant East Bay District's storage works, which at present is approximately the loca- tion of the Mokelumne Hill Gauging Station. or measured as stream flows of the same magnitude are measured by the United States Geological Sur- vey if no station is maintained by it at or near said intake, quantities of water sufficient to maintain the fol- lowing constant rates of flow in the different months of each calendar year: Month Second Feet January.._..._... . ..................................... 50 February.............................................. 50 March.... ............................ :_..__........_...100 April................................................ ..... 200 May_. ..........................................._........200 June.... .............................. ...................... 250 July_ ............................._....__................250 August..................................................250 September ......................................... ...250 October.................................... __........ .200 November .................................... --._.... 100 December.............................................. 50 Provided that when the total run- off, so measured, is down to 120,000 acre feet or less the entire flow- of the river sliail be released at rates of flow approximating the foregoing. 250,000 SCHEDULE When such annual runoff, so mea- sured, is equal to, or greater tban, 90.000 acre feet, but is less than 300,000 acre feet, at the following constant rates of flow: Month Second Feet January................................. _...... 50 February_ ....... ....................... _...._._.... 50 March............................................»......100 April._.............................. _......_.........200 May.......................................... ..---_.200 June................._ ......... July.................. ......... August ......... ............... � __._..__.....300 September . ............... October .... . .... ................ .v----...�.....200 November ............ ....... December ._..__......... 50 ( 13 ) 1NVhen such annual runoff, s0 mea- sured, is equal to or greater than 300,000 acre feet, but is less than 350,000 acre feet, at the following constant rates of flow: Month Second Feet January.................... _ ............................ 100 February..............................................100 March........... .............. _...................... ..100 April......................................................200 May................ _.... I ................ .... .... ........ 300 June........... .................................... _....... 300 July................................................... .... 300 August....................................................300 September .................. .................... .----- 300 October......__.. ................................._.....250 November............................................100 December........ ..................................... 100 When such annual runoff, so mea- sured, is equal to or greater than 330.000 acre feet, but is less than 400,000 acre feet. at the following constant rates of Lion: Month_ Second Feet January............... ...................................100 February..............................................100 March................................... ......... ._...._.100 April......................................................20C May... .................................... ................ 300 June........................................................400 July................. ...................................... 400 August........................ .......................... 400 September .... ........................................ 300 October ......... ............ ........... .................. 250 November ........................... ................... 10C December..............................................100 When such annual runoff, so mea- sured, is equal to or greater than 400,000 acre feet, but is less than 450,000 acre feet. at the following con- stant rates of flow. Month Second Feet January....... .._ ....................................100 February .... ....................... _ ..............100 March...................... ........................ .... 100 April.........._..__. .. ........................... .... 200 May............... .......................... ........... ..300 June............ ............. ...._......._...............500 July.......... . ............................................ 500 August........... ............. _..... . ..............500 September __....... ............ 400 October ......_.._... .............. _......... ......... 250 November ....... __ ...................................200 December ----- . ............. ........................ 100 4ti-ben such annual runoff, so mea- sured, is equal to or greater than 450,000 acre feet, but is less than 500.000 acre feet. at the following constant rates of flow: Month Second Feet January..._ .............................................100 February .................................. _.... _100 March............... ................................. __100 April..................................................... May...................................... _... _........... 400 June....... ................................. _........ —.500 July..................................................... 500 August... ................................... _...... _..500 September........................................... 500 October ... ....................... .....................250 November ......:.................................. _... 200 December... ........ ............................. ..... 100 Provided that if there has not been discharged over the spillway of its refining dam within ten days prior to June Ist, sufficient nater to produce a flow in the river at Clements in ex- cess of 2000 second feet continuing for forty-eight hours, then the re- lea=es shall be so increased as to pro- duce a flow of 2000 second feet for forty --eight hours, commencing on the 1st day of June: and It a like now over the spillway of the retaining dam has not occurred' within ten days prior to July 1st, a like additional re- lease shall be made commencing on Jul; 1st. When such annual runoff, so mea• sured. is equal to or greater than 500.000 acre feet, but is less than 660.000 acre feet. at the following constant rates of flow-: Month Second Feet January................................................_100 February........ ........................ ... .......... 100 March..... .... ...... .................._.........._...100 April....._... _ ........................................_.400 May............. ..._.................. ..... ......... :_.500 June._... ... __........................ ............... W July- ........................ ._........ -... 500 August....... .................................... ...... _500 September ......... ............... __.............. 500 October........... ........ .............. ............... 400 November_...........................................300 December ... _.......... .......................... 00 Provided that if there has not been discharged over the spillway of its retaining dam within ten days prior to Xa.v 1st, sufficient Rater to pro- duce a flow in the river at Clements in excess of 2000 second feet continu. ing for forty-eight hours, then the re- leases shall be so increased as to pro- duce a flow- of 2000 second feet for forty-eight hours commencing on the 1st day of May; and if a like flow {14) 1-----— ' oler the spillway of the retaining acre feet at the following constant dam has, not occurred within ten days rates. of floe =: 4 prior:to _J line.Ist,.a_like:addttional anth - :Second Feet` _ - release_•shall be made commencing on _ - - _ January .- ..... :.... _.::_ L� ...__......,._500 . June_lSt,, and 'if alike flow-oder the February " --.......__�_�._..- ._�_ _500 r spillway of the retaining dam has not March ..__.._.._._.._ _� 5� occurred within tea days prior .to ; AP _ _ July ;lst, ril a like' additional release ' y ' ^ - shall.._be made commencing on July ` Ma �--........._...__ ....__ Y_ -. _$ ...500 June ._... ..�. 500 - - - July .. ._... 00 When such annual runoff, so mea - f ALIgust ...._...__..__ ._.. - -------••--._—.500 sured, is equal to or greater - than= September ........ :....... _......:........._........500 . 600,000 acre flet, but is less. than , i October ............... 80C,000 acre feet, at the following November ............ ...--._...._.___...-----•-- -500 ' - constant rates, of flow:. -December " ......... .....:..... .._ --•. .. ^_ _500 Month Second Feet provided that If there has not been January. ..................... ....... —_::._.200 discharged over the .spillway of its February200 ' ....___.". """"""" _" retaining dam within ten days prior_ - .March ;._.:_._._.......... __..---•----._,.200 , _ .. _.. April •' S00 to'April 1st, sufficient water to pro -_- iMay _.............................. _ _ ._ $00 duce a flow a; Clements in excess of ....... -•� 2000 second feet continuing for forty- - June .._..._.._.. ...................:...._. --^ July _---------------------- ••--•-••-••••---••---500 eight hours, then the releases' shall August ................. .... ................... -_ _ 500 be so increased as to produce a flow. Se t_mber 500 _ October _. ............... __..__....__:..._.._.____50U of 2000 second feet for forty-eight November ......................... :._____.._400:hours commencing on the 1st day.of December ....... _................ -...... -300 April; and if a like flow over the Provided that if there has not been spillway of the retaining dam has not I discharged over the spillway of Its occurred within .ten days : prior .to retaining dam within ten days prior May 1st, a like additional flow over. to April 1st, sufficient water :to -pro- the spillway of the retaining dam has - --. duc_ a flow at Clements is excess of not occurred within -ten days prior to 2000 second feet continuing for forty- June .Ist,.`a _.like . additional release' = :T eight hours, then the'releases'shall shall be made commencing June 1st; =: be so increased as -to produce 7a flow, 'and if a like flow over the spillway of -:7 of 2000 second. feet for :forty-eight the retaining dam has. not occurred._. -s = hours commencing on-the'lstday:bf' within te¢ d3Fs prior tb_JulY--'IS April;.and if _a _like ,flow: over thee additional releaseshall be made spillway of.the retaining data has not - commencing July 1st. occurred within ten days prior'to'- ay _ All of said relerses to be measured lst,.a like additional release _shall be at the location of the United States_•." made commencing on 31ay 1st; and if •Geological Survey gauging -station at= *a like flow over .the spillway of the .. Clements, as -.the river ' runoff retaining dam has not occurred with__ measured above the reservoir of -the in :ten daps prior .t6. June1st, a like,. -defendant = East Bay District, -'eacept f additionalrelease shall be made'c_om= at .in the event of any use, _intercep--_-i Kms_ VFW -mencing on Tune ist;.'and.if,a like iion-or diversion of the waters: of the;h -_�- flow over the spillway of the retain -_-river ocimirini :belowe-`Dres.a '=. _` i� ing dam. has not .occurred within ten. - . _ - - works of the said -defendant "in ;add1.. days prior to July 1st, a like addition--_tionto aap' now't stin g.'other •than : ; �:. al release -shall, be -made commencing suc_h..as.it•may.institufe, -the'said •ie= `- _'.' on July,l5t ' ;'= -.: _y ,leases =shall be `so ^measured abobeY - - ,-' Whea such'-annual;flaw someasur-.=suchanterveain nse-inferce tfoaTor`--:. _ lg D 'ed is equal to or greater than 800,000: diversion _:�- Sz M. RELEASES PARAMOUNT _ -,• = - , _SUPPLY ASSURED ;:•;, _:_ The decree should further provide With the East Bay District operat- -_ that the defendants are the owners Ing at its maximum capacity,' aad and holders of the permits issued to''diverting 224,000 acre feet, approxi- mately one-half of its demands would 7 - them by the State and Federal gov be met It now has reserve storage ernments, and that -the right of each - facilities affording a six months' sup - to the use of the waters of the Moke- ply. It is to be assumed that as its = lumne River, over and above there- requirements - increase Its reserve leases which each is required to storage facilities will be increased proportionately. So, in the most criti- i make, is paramount to that of the cal years operating at its maximum -7 plaintiff; also that any releases of capacity it will not -be without an ade- water by either defendant in excess quate supply of water. of those which it is required to make The provisions that the East Bay ' will not enlarge the right of the plait:- District provide from its storage alone tiff, and any benefit resulting to the the flush flows of 200,000 second feet plaintiff by reason of any such re- are equitable as they are to be made _ .leases, or any use which the plaintiff at .times when the constant flow re- - leases Df the Pacific Gas and Electric may make thereof, shall be permis- 'not Company are more than sufficient to sive and adverse to. the right of cover the 310 second foot maximum either defendant. diversion of the East Hay -District. The releases provided are deemed \either can Lod[ complain that they adequate to supply a percolation into are not provided for In seasons of ==' •`-. the Lodi area as great as that oc- comparatively light runolf as In such _ - •s curring under natural conditions, to seasons the summer releases are a - prevent unnecessary waste, and to drain upon carry-over storage. _. • -•Z- meet the legitimate demands of all COUNSEL COMPLIMENTED. the parties. With the flow of the Counsel for all parties are to be J•,_,ya stream as in 1931, augmented to a complimented upon th'e exhaustive " 4' runoff of :10,450 acre feet by the preparation and efficient presentation ' Pacific Gas and Electric Company re- made of this -case, the. courtesies ex- leases, which is the lowest known hibited throughout• the trial 4vhich ==':: - flown flow as regulated, occurring made of it i most pleasant associa- above the Pardee Dam, 90,000 acre tion, and their sincere -endeavor to - - feet would be diverted by the East reach a correct solution of the diffl- _ -i_'- - Bay District, satisfying its present cult problem of providing for the ia•y "'needs to the full; 120,000 acre feet habitants 'Of the City of iodt .ana =.^ - would go downstream; of which 7,000 their -neighbors an artificial supply of acre feet would be pumped from the water as adequate as that -bestowed --river by riparian owners; 65,000 acre upon them bynature. M, feet would be diverted by the Wood • Counsel for plaintiff are directed to _ - bridge Irrigation District; and 48,000 - acre feet would be left for percolation prepare and present such•findings.of - . into 'the Lodi area. --None of the re- tact and conclusions of law as may--- ay-_-leased leasedwater Nvould be wasted as the be appropriate and in accordance with - *<_ maximum releases of 259,000 -second -the •.views herein expressed. feet =occur at :the -peak of the- 'irriga- _;--a`when:the diverting -canal Aicn seaso -- Dated this -20th dap, 01 :_January, _ �oL .the Woodbridge 'District; -.with a .1933 ; 'C. 'TOirES,' capaclty.of 250:second:ieet,: would'be • - =�; =BEtiJAh_SIN l .-t- _ taking ail the Rater it could _ -- 'Judge of the Superior` Court ". - - -. - I, History of Development of the City of Lodi and Contiguous Rural Vicinity. The City of Lodi is a California lunicip_lity of the I sixth class situated upon the mainline rails:-d of the Southern Pacific Railroad Company about fifteen miles north of the City of Stockton and about thirty-five miles south of the City of Sacrzmento, the California State Capitol. The City of Lodi was founded in 1869 and was incorporated In 1906 and has grown until it now iias a population of approxi- mately 7,000 persons. The territory contiguous to the City of Lodi is in a high state of cultivation. The area, within a radius of sip miles of the City of Lodi is planted almost exclusively to vines, trees, alfalfa, truck gardens and the like. Because of the abundance and quality of the Tokay grapes raised in the District, Lodi has be- come known as the Tokay Center of the World. There is shipped by railroad to the eastern—z-kets annually an average of approxi- ma+,ely 6,000 carloads of grapes from the Lodi territory. Some 3500 carloads of grapes are locally used by wineries situated in the District or in nearby communities. In addition, there are large annual shipments of orchard fruits, truck garden products and the like. The vineyards, orchards, truck garden produce and other crops raised 4n the territory are irrig:cted in the main from wells driven into the underground rater table. Inds favorably situ- ated pump water directly from the Mokelumne River. The annual power consupption for the pu=7s in the territory is given by the United States Geological Survey in a recent release entitled "Pumpage of Ground Water for Irrigation in the Yokelunne Area, - 1 - California", dated November 13, 1933 (a supplement to Bulletin No. 619)at approximately 9,500,000 kilowatt hours per year. The area irrigated by ground water has progressively increased from approximately 5,000 acres in 1909 to 50,000 sores in 1927, according to government reports. The dean annu=l precipitation in the Lodi Yokelumne River -Area is approxim-a tely eighteen inches. In addition to this, orchardists pump from 1.3 to 2 acre feet per acre on the average; vineyardists from 1.4 to 2.1 acre feet'per acre; alfalfa requiree from 2.2 to 4.5, while miscellaneous crops raised take from 1.3 to 2.7 acre feet per acre, depending on the season to produce the quality of crops" grown. The mean temperature of the City of Lodi is approximately sixty degrees Fahrenheit with a nean naximuW of approxi=ately seventy-one degrees and a mean minimum of approxi=a telt' forty- six degrees. The contiguous territory generally referred to as the Greater Lodi Area, is the most thickly settled and populated Rural Area west of the Mississippi River. The population, according to the 1930 census, was approximately 18, 000. persons. The area is subdivided into many thousands of scall farm units, there being as high as eighty homes per square mile in parts of the'territory. II. Public Utilities of the City of lodi. (a) water works SysteA. Previous to the year 1910 the dater Works System serving the City of Lodi and its inhabitants was privately owned. In 1910 the City of Lodi purchased the privately owned Water Works System, and because of the insufficiency of the privately owned system, due to the rapid grcwth of the City, immediately in- creased the number of wells, pumps, fire hydrants, mains, etc., including theerection of a 100,000 gallon steel, elevated tank, and has subsequently operated the pumping and distribution sys- 2 _ 1 tem as a municipal enterprise supplying water for municipal, commercial, industrial and domestic use within the dity of Lodi. The Water Works System at the present,time derives water from five wells by electrically driven pumping plants. The system consists of a 100,000 gallon steel tank and approximately twenty-five miles of water mains, serving approximately 2,000 domestic connections, twenty-five industrial connections, 300 - commercial connections and 185 fire hydrants besides serving the City Hall, fire houses and other municipal buildings and public improvements including the City Library, five gramar schools, one high school, twenty-three churches 4nd three municipal parks located within the City Limits. The system furnishes as high as 6,000,000 gallons of water daily, and an average of about 3600 acre feet annually to the Inhabitants of the City of Lodi. The water rates within the City of Lodi are unusually laws. the bulk of the service being rendered on a flat rate basis. Domestic service is rendered at a flat rate of $1.50 per month, and other flat rates are proportionately low. Metered service for commercial, industrial, and optional domestic service is rendered at a rate of 7;e per 1,000 gallons plus a monthly meter chF.rge ramging from 50j„for o=dinaryiservice up to ,$c4.00 per month for large, industrial, 4, --inch meters. The net profit of the Water Works Department for the three years last past has been approximately $19,000.00 par year, after deducting all operating costs, bond interest and redemption charges plus depre- ciation and replacement allowances. -,..-L The. ground water table from which the system seri/ves its supply is maintained by waters percolating fro= the waters of the Yokelumne Piver. The City of Lodi has as an appropriator of the waters percolatin„ from and the underfloor of the Yokelumne River since' 1910, acquired a right to the use of 6,000,000 gallons daily and 3600 acre feet per annum. The mumps used in connection with the Municipal 'Mater Works System are driven by electrical energy obtained hrough the Municipal Zlectrical Distribution System of the City of Lodi. (b) Zlectrical Distribution System. The City of Loci as a municipality acquired the Ziectrical Distribution System in the year 1510 and has since been dis- tributing electrical energy to its inhabitants, industries and various municipal and public enterprises. During the past three years the City of Lodi has purchased for distribution . an aze:age of approximately 6,000,000 kilo- watt hours of electrical energy per year upon a rate basis es- tablished by the California Pailroad Commission, which rate has averaged nine stills per kilowatt hour. Besides lighting Lnd heating municipally owned properties and operating its utilities, the City of Lodi distributes elec- trical energy to approxi -mately 2400 consumers, of which approxi- mately 2,000 are domestic, 350 co=ercial, and 50 industrial users. It is to be expected that with the return of normal economic conditions, the electrical energy consumption within the City of Lodi will increase particularly with the increasing numbers of light industries and the use of electrical appliances. This will be especially true if the energy rate is lowered. Through the distribution and sale of.electrical energy, the City has realized a net profit of approximately 135,000.00 per year for the three yea_:s last past after deducting bone, re- demption and interest the whole sale cost of electrical energy purchased (including that used for muni0pai nu os s) overhead, - and erhead,- and operating expenses including :tteit-9 depreciation enc replace=ent charges. The consumers' electrical rates are approxi- mately 75% of those charged by the Pacific Gas and Electric Company for similar service in neighboring cities and in the con- - 4 - i tigucus rural territory. 2xclualve of the energy sold by the City of Lodi to private consumers; of the electrical energy purchased ;wholesale by the City of Lodi during the past tired fears, an average of 833,000 kilowatt hours has been used in operating the municipr.l pumps of its grater Works Systeaj,, 265,000 kilowatt hours in operating its municipally owned/ISewage Disposal Plant, 288,000 kilowatt hours in lighting the streets, and 150,000 rilowatt hours in lighting and'heatina public buildings, and for other miscellane- our municipal purposes. At the present time about 25: of the electrical energy purchased wholesale by the nunicip&'A system is used for strictly municipal purposes recited above. III. 3lectrical Develonnent Outside of the City of Loci. The contemplated. Rural District contiguous to the City of Lodi to be served with electrical energy subsequent to the com- pletion of the Lodi Power Project, comprises approximately forty- four square miles and lies wholly within what is known as the Yokelumne River Area or the Greater Lodi District. The Rural District is indicated on ?..xhibit herewith attached. There are approximately 900 consumers within the district who are now purchasing electrical energy from the Pacific Gas and Zlectric Co=an.y, the public service corporation noir serving the area, for the operation of 865 irrigation pumps e' eS'ic water supply, lighting homes and operating other appliances. During the past five years the amount of electrical energy re�uired* by the dis- tribution system within this Rural District has been approximately 8,000,000 kilowatt hours per ye�-r. The average rate paid by the consumers is approximately 2j4 per kilowatt hour, amounting to some $180,000.00 per annum on the average. As the Rural District is brought under a still higher state of development and the population increases, the electrical service used will be increased. N. Geographic Conditions. - 5 - IV. Geogranhic Conditions. (a) Mokelumne River Drainage Basin.. The Mokelumne River heads in the Sierra Nevada Mountains about one hundred miles Northeasterly of the City of Lodi and flows in a general Southwesters; direction to r. confluence with the :San Joaquin River. Like all Sierra Nevada streams the flow of the Mokelumne River varies greatly in different seasons of the year. In its natural and unreouluted state, h-4r_h flows of as much as 60,000 cubic feet per second, have occurred, whereas the low flow is approximately 100 cubic feet per second. The high flow is usually attained in the spring -months and the low flow in the summer and fall. The runoff of the strew_^_ varies from approxi- mately 1,600,000 acre feet per year to approxi=ately 200,000 acre feet per year averaveinn about 500,000 acre feet per year. The North Rork contributes the greatest snow pads runoff and the South and Middle forks contribute the more flashy a. -id torrent"al flows. The Mokelumne debouches from the foothills at Clements, approximately eleven miles easterly of the City of Lodi,, and flows across the San Joaquin Valley into the Delta Region about ten miles :Westerly of the said City. The Mokelumne River has built i up r.n alluvial fan or Sas ...;mc -.n as Sanford fine, sandy loam an which the City of Loci is situated. It is this recent geological for=ation that is in a great part responsible for the grotith of the City of Lodi and its contiauaus Rural territory. (b) San Francisco Bay Area. Th e =,ast Bay ':unicipal Utility District is composed of nine municipalities situated on the San Francisco Bay e:-Lsterly and across the Bay from the City of San Frcncisco. This district embraces Oakland, Berkeley, Alameda, P.ichaond, Piedmont, Albany, San Leandro, -7=eryvilie Lnd 51 Cerrito, and has a present popula- tion of appro:tieately 500,000 persons. The said District Water Supply is transported across the San Joaquin Valley through some ninety miles of aqueduct leading from the 11okelumne River Pardee �7M Reservoir to several reservoirs located near til: said District. "'Mbit Y. Pacific Gas and Electric Comoanv xokelumne river Develoaments. (a ) Mild Wor?"3 . Prior to tiie year 1525 the Pacific Gas and •Electric Company had for some twenty years owned and operated certain hydro- electric worL�s of minor importance on the morth Fork" of the Mokelumne River. These old works consisted of five R -all reservoirs with a total storage capacity of some 26,000 acre feet, whic!i were used for the purpose of storing _nd regulating a portion of the natural flow of the said P.iver thereafter passing the s=-- a through z%c Mectra Power Plant and returning the said :asters to the channel of the stream, a;ccepting a _ ative sra11 amount of such water which was diverted away from the stream for domestic and other uses. The above-mentioned uses and d;versions made by the said cozapa.-iy have ripened into present prescriptive rights and are prior to the rights of the Cit_ of Lodi and others. However, the said rights ire relatively s-111, representing about three percent of the average annual runoff of the Uokelumne River. (b) New and Proposed Works. Subsequent to:the year 1925 the Pacific Gas and Electric Company obtained by.rederal Power CO=ission Project License No. 137 � the right to use certain lanes of the United States i Government lying in the water shed of the North Fork of the Mokelumne River for reservoir and power house purposes. Prior to obtaining the said Project License the said company obtained certain permits frari the California Division of Water Rights, permitting diversion to storage of certain waters, and the use of the same, together with the natural flow of the said Horth Fork through certain existing and proposed power plants, all - 7 - crater to be returnee to tin:: :lain ch_:nnel o= the said r i•rer above the Lodi Power Site. Pursuant to t -he- sc is license _nd ?ernita, the Pacific Gas and electric Company has constructed the Salt Springs Reservoir of a_proximately 130,000 acre feet storage capacity, together with certain pipe lines, aqueducts and power houses known as the brew Works. The said company holds further licenses end permits to construct proposed Lower 3ear and Beer Valley i eservoirs which, if constructed, Would have a combined stcrage capacity of approxi- rately 60,000 acre feet. Zia Said Co_patir no:f has a :total storage capacity on the M rth For:: of the jio_elumne river of approximately 155,000 acre feet. In the operation of the above reserzoirs the said, company proposes to store the high flows of the Mokelu=e River, and to ernually use tha scz,e through its power houses, for the purpose of auG—_enting the lav floe a of the River. reo.lated flow of the Horth : ork of the 1�okelu=ne will appro::imate 500 cubic feet per second except during periods o: spillway discharge aid extreme drought. i Under the decisions of the California nupre::e Court, it has been uniform.;; held that these permits issued by the California Division o2 Water Rig hts are permissive only, and the the said permits have the effect cf grrnting to the said Company no new j rights, ltirther, the California Courts have uniformly held. and C it is alsc definitely recited in each of the said permits, that said pe=lts are -ranted sUb ect to Dr1or vested rights of all downstream proprietore, vested water users and ap_ropriatora. Because all of the said Company's Mokelu=e River works are situated upstream from the . o•rrer site of the City of Lodi, all } Raters regulated and released by the said company, excepting the B=all diversions for domestic and other uses in Jackson. Sutter Creek and Amador City and excepting interferznce by the works of the P<st Bay Municipal Utility District, will flow down and over - 8 - the City of Loci's Power site. The State of California adheres to the Riparian Rights Doctrine. The City of Lodi, as :,mer of the said power site, Including lands in the bed =nd on both banks of the main Mokelumne River, below the confluence of its three principal forks, is a riparian proprietor. Therefore, such rights as may have been obtained by the Pacific Gas and Electric Comp any through its said permits were obtained subject to the riparian rights of the City of Lodi as appurtenant to its suid lands. The City of Lodi in pumping its municipal mater supply from the underflow-of t:e Kokelu=ne River within the corporate limits of the said City has acquired an appropriative right by prescription to the underflow of the said strear. Such rights as the Pacific Gas and Rlectric Company may have acquired through the new permits are, t_erefore, subject to the said appropriative rights of the City of Lodi and the ri,3ht to have the underground water table replenished and maintained to the sane extent as the natural underflow of and percolation from the :2okelunne River. VI. last Bay -Municipal Utility District Mokelumne River Developments. The 3ast Bay Municipal Utility District was incorporated in the year 1924 under a special act of the California Legislature, and by vote of the people within the s -:-Id district. In 1926 the East Bay Uunicipal Utility District obtained from the California Division of Water Rights its o=iginal municipal Persit which authorized the district to divert annually to storage in its Pardee Reservoir up to 217,000 acre feet from the flow of the Mokelumne River, and use the sane for beneficial, municipal and domestic purposes; and further, to divert from the natural flow of the staid river to .the East Bay Municipal 'Utility District, not to exceed 310 cubic feet of water per second continuous flow during each year, the combined diversions from natural flow and - 9 - storage not to exceed 200,000,000 gallons of water per day. The amount of water which the East Bay Municipal Utility District may divert for beneficial use will not exceed 226,000 acre feet per year or practically one-fourth of the normal annual stream flow. Such waters as estimated by the District officials at the time of filing its said municipal ;water application, will supply a popu- lation of 2,000,000 or four times its present population. The said Municipal Permit, as issues, by the State Division of later Rights, contains a reservation that no water taken by the said District shall be used "for other than Municipal purposes within the boundaries of the Dast Say Municipal Utility District" and that "this permit is issued subject to the express condition that the use hereunder may be regulated". Subsequent to the issu- ance of the aforesaid municipal permit, there were two power per - nits issued by the Division of Water Rights, whereby said Fast Say Municipal Utility District may use through its Dower house, at the base of the Pardee Dan, up to 750 cubic feet per second of water for the generation of electrical energy. Such water may be taken either direct from natural flow or from Pardee Reservoir storage in excess of that needed for municipal uses. Subsequent to the issuance of the aforesaid State dater Permits, the District obtained in 1926 by Federal Power Commission Project � License No. 567 authorization to use for municipal and power 'pur- poses certain lands of the Federal Government upon which the said � Pardee Dam and a portion of the Reservoir have since been construct- ed. The said district first stored water in its said Pardee Reservoir, in March, 1929, and the initial diversion of water through the aqueduct to t1e District was rade shortly thereafter. The permits issued by the Division of Water Rights to the East Bay Municipal Utility District were also expressly issued - 10 - subject to X11 prior vested rights. Therefore, under the very terms of the said permits and under the decisions of the Supreme Court of the State of California, the said per --its granted no rights to the East Bay Municipal Utility District which were not subject to the prior riparian rights appurtenant to the power site property of the City of Lodi, and also subject to the prior appropriative rights of the City of Lodi, to pump and divert the underfloor of the ]doelumne River for municipal and domestic uses. VII. Acquisition of the City of Lodi's Power Site. In January, 1929 the Colorado Power Company, a Calif orris corporation, transferred and conveyed to the City of Lodi in fee 207 acres more or less of land situated in Amador and Calaveras Counties, contiguous to and divided by the Mokelumne River. to which the lands are riparian. 7he upstream boundary of the'Ladi Reservoir Area is im`ediately below the Pardee Da= and poker house of the Zast Bay Municipal Utility District. VIII. Litigation Affecting the Floe: of the Mokelumne Rive:. (a) Colorado Power Company vs. Pacific Gas and Electric Company. Prior to the conveyance of the Mokelumne River Power Site made by the Colorado Power Company to the City of Lodi, the Colorado Power Company commenced an action in the Superior Court of the State of California in and for the County of Calaveras against the Pacific Gas and Electric Company. This action was based upon the riparian rights attaching to the fee lands of the Colorado Power Company. In said action the Colorado Power Co=pany sought an injunction against the : (b) Company, by the said Superior Court. An appeal from the judg- ment was taken by the Pacific Gas and Electric Company and after being submitted twice to the Supreme Court of the State of California, the final decision of the said Court, affirming the said judg:nent,was obtained in July of 1933. The judgment thus affirmed provides that the Pi-cific Gas and Electric Company shall be restrained from storing any of the waters of the North Fork of the Mokelur--ie River and from Interfering with any of the waters of the said river, excepting the operation of the Old Works, unless the Pacific Gas and ylectric Company shall operate its new works to regulate the waters of said riven in the manner hereinafter recited. A cer- tified copy of said judgment is filed herewith as Zbchibit Were it not for the fact that the Pardee Da: and Reservoir of tree East Bay Municipal Utility District is situated between the return to the Mo'selumne River Channel of the regulated flow from the Pacific Gas and Plectric Company's works and the City of Lodi Reservoir Site, the regulation required under the Judgment Joverning the operation of the Pacific Gas and 3lectric i Company would pass down and over the Loci Site and be available for the generation of power by the City of Lodi. The said judgment in favor of the Colorado Power Company against the Pacific Gas and ilectric Company has inured to the City by virtue of the transfer of ownership of said lands from the Colorado Power Company to the City of Lodi. City of Lodi vs. cast Bay Municipal Utility District and East Bay Municipal Utility District vs. City of Lodi - Calaveras County Litigation. I Subsequent to acquiring the Power Site from the Colorado Power Company, the City of Lodi commenced an action against the f East Bay Municipal Utility District in the Superior Court of the State of California in Lnd for the County of Calaveras, based upon the riparian rights of the City of Lodi to the waters of the river through the ownership of the 'Power Site for the purpose of restraining and en,;oinin5 the East Bay Municipal Utility ,2 District from storing, diverting, or otherwise interfering with tie flow of the :lokelumne Fiver. Before t.%is case could be brouSht to trial, the Last Ba,; Vunicipz�l Utility District brought an action in eminent domain In the Calaveras County Superior Court Lgainst the City of Ledi for the purpose of condemning and acquiring the right to store and divert the waters of the Mokelunne River in accordance with the plans of the 3ast Bay 3iunicipal Utility District and the per- missive rights granted by the said permits 4nd to extinguish the said riparian rights of the City of Lodi, only insofar however, as such extinguishment mi -ht be necessary for such purposes. The purpose of said eminent domain proceeding was not to condemn the fee of the said power site, either in whole or in part, nor to condemn all of the said ripari"n rights, but was for the sole pur- pose of extin--uishing the said riparian rights of the City of Lodi only to the extent that it might be necessary to consummate the plans and proposed operations of the cast Bay Municipal Utility District as recited in the district's Municipal and Power Permits. These two cases, (the City of Lodi's injunction suit, and the East Bay 'tunicipel Utility District's condemnation suit) were consolidated and tried together. As a result of this action, it was decreed that the East Say Municipal Utility District had the right to condemn the riparian rights of the City of Lodi to the extent onl,r that might be necessary for the above-mentioned pur- poses of the s�.ic district, and an award of 1125,000.00 damages was made in favor of the City of Lodi, which has been paid to the said City. In the action the injunction sought by the City of Lodi was granted, unless the said aware of y25,000.00 be paid. The payment of the said award, therefore, had the effect of deny- ing the said injunction. It should be here pointed out that while the said District acquired by condemnation the riglit to ultimately divert up to 310 cubic feet per second continuous flow to t.ae Last Bay Cities - 13 - 1 the amount of the present actual diversion is less than 70 cubic feet per second. 's`rOm the variance between the estimated munici- pal requirements necessary during 1933, made at the ti:ae of filing the municipal application with the State Division of :Vater Rights, and the actual 1933 diversion, it is obvious that the original estimate of making beneficial use of the maximum diversion of 310 cubic feet per second in 1980 was unduly optimistic. The effect o: these two judgGvaents is to leave the City of Lodi holding the fee of its said power site and its riparian rights intact, except to the extent that said riparian rights may be interfered with by the operations of the -East Bay Municipal Utility District, as limited by the conditions of the said permits issued by the California Division of Water Rights, and further limited by the judgment rendered by the :.superior Court of ,San Joaquin County as hereinafter referred to. A certified copy of the said Judgment of Condemnation is filed herewith as Zxnibit (c) City of Lodi vs. East Say Minicip-cl Utility District and Pacific Gas and .electric Company - San Joaquin County Case. In December 1929 the City of Lodi commenced in ti.e Superior Court of the State of California, in and for the County of San Joaquin, ar, action against the -East B -y Municipal Utility District and Pacific Gas and electric Company for the purpose of obtaining an injunction restraining said defendants from storing, diverting or otherwise interfering with the waters of the Mokelumne River. The City of Lodi alleged that it owned and operated a dater Rorke System and punned water from the water -table underlying the City of Lodi and that said water -table was fed and maintained by the underfloor of and percolation from t. -.e Mokelu=ne River and that the City of Lodi was therefore an appropriator of the waters of the Vokelumne River and had established its right to such appro- priation by prescription, and, that the proposed joint operations of the defendants would diminish the percolation.and underflow from the river into the water table then already overdrawn. - 14 - The Pacific Gas and Electric Company filed an answer setting up its proposed plan of operation and offered to be bound by the court judgment compellin3 it to so operate. The z-;.st Bay Municipal Utility District filed an answer deny- ing that the City of Lodi was ar appropriator of the waters of the 31okelumne River and denying that its open"tions would in any way damage the said City, and alleging that there were excess• waters in the river which flowed to the sea and wasted. This case c4 a on for trial upon the said issues in'September of 1932, and lasted several weeks before submission to the Court. In J_nuary 1933 the trial court announced its decision in favor of the City of Lodi. thereafter findings of fact ::nd conclusions of law were served, filed and settled and judgment was signed and filed by the trill court in August of 1933. In the s«id findings and Jud-sent the court decided that the operations of the pacific Gas and Electric Company would, if conducted in the manner proposed, not diminish the percolation from the river into the underground water-6-able, and the court in the judgnent directs this defendant to so operate. The findings further decided that the so-caller. "Grunsky Release Plan" offered in the said case as a stiulation by the eleas 1 ff py _ said District as how it would be willing to be bound to operate. was sot sufficient to insure the City of Lodi that percolation fro= the Mokelumne River would be equivalent to that which would prevail under natural conditions, and therefore, enjoined the Bast Bay Uunicipal Utility District from storing or diverting any of the waters of the Mokelumne River unless it scall overate ite storage works and make releases in a manner therein set forth. A certified copy of the said San Joaquin County Judgment and Decree io filed herewith as 21xhibit Since said judgment was entered both defendants have made motions for a new trial and to correct and modify the judgment, which motions have been denied. Said defendants have both per- - 15 - fected an appeal fro= said Judgment to the Supreme Court of the Stats of California. The Past Bay Municipal Utility District as heretofore re- cited, obtained, in the superior Court of Calaveras County. a Judgment in condemnation extinguishing, to the extent necessary for the proposed operations of the 3ast Bay Municipal Utility District, the riparian rights appurtenant to the City of Lodi Pourer Site. Notwithstanding this fact it is quite obvious, from the terms of the San Joaquin County Jud,ysent, that by reason of the country topogra?hy and tha up=_trea=- boundary of the Lodi Reservoir Site _n: the downatr a= bDundary of the P-rdee Dz= Site being coincident, . (Ile Lodi Power Site lying do:rnstre= fro= the Pardee Dem of the .;ast Bay Minicipal Utility District, it is isspossible for any appropriator to physically divert :-term Which flow over or thronh the said Pardee Dam pursuant to the said judgment, and said waters will necessarily flow over znd across the Lodi Power Site. At the said Calaveras County trial the said District witnesses testified that the average usable daily flow i at the Lodi Site under regulation by the said District Honks mould ; be fro= 690 ciibic feet per second down to 525 cubic feet per second under successive stages of regulation by the said District as shown by the said District's Exhibit "DD", and further, that even in low flow months and with the ulti=ate aasi=um diversion. of 310 cubic feet per second to the Wiest Say Cities the release at the Pardee Poorer Plant would be a daily mean of 345 cubic feet per second. The said :witnesses also testified as to the favorable power out- put which will always be available under the District regulation as shown by the said District's xhibits "II". Objection by Lodi counsel as to the ad=issibility of the aforesaid y.hibits as not being based on any contract or decree were stet by the District counsel with to statement that the said District "can't operate In any other may." 16 - We would point out asain that the City of Lodi is t. -&e owner of the said 4ud6r^e_nt rendered by the Superior Court of San Joaquin County and that while said „udgmer.i. is based upon rights in and to the underground water -table, -evertheless the City is in a position to enforce the s:ic judgment. Assuming the judgment and decree in the said San Joaquin case were ren- dered inoperative, the quantities of water to be e:c3ected at the Loci Power site, on the basis of operation by t:_e East Bay Runicipal Utility District substantially as set forth in the proposed method of operation as the "Grurns{y Release Plan", might be so,_ewhat�l from t!t expected under the said decree, however, when checked against the operation .orogran con- templated by the said District, the decreed me'-bod of operation as submitted by the District in the said case a_n_ known as t}.e "Gruns::v Operating Plan", Sz'ibit "3-19" of the said District, shows that the actual releases conteslated therein are in excess of the releases required by the said judnent and decree. Undor t:e Colorado Po•.ver Com?anr vs. ?acific Gas and Electric Company jud&ment the latter company is bound to release into the Mokelumne River, above the Loci and Pardee Reservoirs, an average i of 475 cubic feet Der second of grater, for each calendar day, so long as there is water in the Pacific Gas and Electric Company's old and new storage worts and/or flowing in the North Fork of the Mokelumne River. This 475 cubic feet per second exceeds by 165 cubic feet ger second the maximum authorized and anticipated municipal diversion of t: --e Zast Sag 3iunicipal Utility District of 310 cubic feet ner second irrespective of permitted storage in the said Pardee ?eservoir of 217,000, acre feet, whic-h of itself is sufficient to provide one year's rater supply for tre said Resat Bay Municipal Utility District irrespective of its local storage adjacent to the said District. The naexpected diversion to I the =ast Bay :Municipal Utility District in 1935 is only 70 cubic feet per second or approximately 22j% of the ultimate diversion or - 17 - apvroxirately six : ..:.percent of the average daily flow of 1130 cubic feet per second of the Mokelumne Fiver as measured at Clements by the-Lhited States Geblogical Survey during 1905 to 1928 inclusive. The difference between the afore- said average daily flow and the proposed ultimate diversion of the said District of 310 cubic fee per second'is available for re -regulation by the 3ast Bay Municipal Utility District for use In the generation of electrical energy. It is most problematical If and when the said ultimate diversion of- 310 cubic feet per second will be made to the .hast Say District. IX. Physical Characteristics of Vm Lodi Power Site. In the condemnation suit entitled East,Bay Municipal Utility District vs. City of Lodi, and in the case of the Colorado Power - Company vs. Pacific Gas and Electric' Company, both of which were. tried in t -he Superior Court of Calaveras County as aforesaid, the Court found that the City of Lodi hydroelectric property'. im- mediately below the Pardee Peservoir, was valuable as a power site. This finding was affirmed by the Supreme Court of the State of California. The language of said finding is as follows: "The plaintiff and its grantor have for several years been proceeding with plans for the development upon said riparian land of a low head riparian power project. The physical characteristics of the plaintiff's lands are such as to admit of the construction thereon of a low head hydro -electric power project and the production of electric energy by weans thereof. The agricultural and industrial demands for electric energy in the territory adjacent to plaintiff' proposed project are such as to economically justify proposed power cevelopment." This finding was based upon the natural flow of the Mokelumne River. Subsequent to the said finding being made and subsequent to the termination of the Calaveras County litigation fixing the regulations and releases herein enumerated, tp_�c City of Lodi has obtained the judgment in San Joaquin County litigation previously mentioned during which trial was tendered the "Grunsky Release Plan", with any of the foregoing regulation and release conditions together with the fact that the Pacific Gus L-nd Electric Company and the Last Say Municipal Utility District have constructed - 18 - ]fokelumne River storage in excess of 370,000 acre feet, which storage is to be used in regulating the flow of the River, such regulated flow, excepting diversions as may be rade for munici- pal and domestic purposes previously mentioned, assures to the City of Lodi a regulated floss over its power site. Such regulated { flow, actually passing over the Power site owned by the City of Lodi, will be far more beneficial for the generation of electrical . energy than the use of the natural flow of the dobelu=ne River; with which natural flow the Calaveras County Superior Court and the Supreme Court of the State of California found that the City i of Lodi had a feasible Power Project. In the Calaveras County case the said Superior Court further found: "Considered solely with reference to physical effects, defendant's proposed i=pounding and storage of :nater in said Salt Springs, Deer Valley. and Lower Bear River reservoirs and its proposed regulation of the natural flow of water in said North fork, by means of its storage of water in said reservoirs and discharge of stoz•ed waters therefrom, as proposed by defendant in Its said additional defense, will not interfere with any actual or anticipated beneficial use of the waters of the Mokelurne River by the plaintiff upon its riparian lends, j or damage or diminish the balue of said lands. if defend- i ant shall actually return the regulated waters into the channel of the Mokelumne River, at or above the tailrace of said Electra Power House. in accordance with the plan of operation set forth in its said additional defense; but, on the contrary, such impounding, storage, release. regulation, and return of the waters of said North Fork will be beneficial to the pla`ntiff, and will increase the value of plaintiff's said riparian lands for use in the generation of electric energy, if the waters to be stored and released, as proposed by defendant in its said pro- posed reservoirs, shall, after their use and return to the channel of the Makelumne river, at or above the tail- race of said Electra Power House as proposed by defendant. actually flow down the natural channel of said river to and over plaintiff's said riparian lands." Annexed hereto and marked "Exhibit " is a contour map showing the exterior boundaries of the power site fee property of _ the City of Lodi containing 207 acres, more or less, the fee prop- erty necessary to acquire by condemnation or otherwise from one Stephen Z. Kieffer together with the United States Government land the use of which is to be acquired under a license from the Federal - 19 - Power Commission, necessary to permit of the construction of a fifty-nine foot dam^. The reservoir nap also shows flow area con- tours, the dam and power house locations and various water eleva- tions and measurements along the stye— bed. It will be noted from this plat that the property owned by the City of Lodi is in two separate parcels. The difference in elevation between the upper and lower boundaries of the lower or dam site parcel is sufficient to permit of the construction of a dam forty-nine feet hien, whereas, if the two parcels are consoli- dated, cinder the present plan, by condemning the reservoir flow {i area of the Kieffer property and by obtaining a Federal Power Commission license permitting the use of the flow area to be flooded, sufficient reservoir area will be available for the.con- struction of the fifty -bine root dam, In January 1929 the City of Loci filed a condemnation suit i in the S-uperior Court of Calaveras County, against the said Stephen Kieffer and Pacific Gas and .3lectric Cospany for the purpose of eondemnin,, the said Kieffer property and certain stream diversion rights which were then understood to be owned by the Pacific Gas and Electric Company, but which subsequently Were conveyed to the said Kieffer. These so-called diversion rights have never been availed of and are merely some old ditch rights granted in an ticipa- tion of =inina' operations. Irrespective of any present worth of such privately held diversion rights, the applicat--on and use of {1 such would necessitate the passage.of the water diverted over and across the fee land of the City of Lodi.. Under California law such a right could be obtained only by negotiation. The Kieffer � land or flow area necessary to be acquiral conaists'.of seven and one-fourth acres more or less and as aeaeured along \the`ketream bed t- - represents llp of the total lineal distance of the Lodi Projects-���r. It has a difference in elevation, between its upper and lower boundary, of 1.33 of a foot or 2,22% o; the total head '-available for the i,odi Power Project. Individually the Kieffer property is - 20 obviously insufficient for reservoir use and only has.a nominal value for grazing purposes. The condemnation suit against the said Kieffer is still pending and the City proposes bringing it to an Immediate hearing when the herein requested loan to the City 14 granted. Filed herewith, marked "Zxhibit is a certified copy of the suic-.tieffer complaint in e.^:inent domain. The United States Government land necessary and proposed to be acquired by license consists of four and one-half acres more or less, having a lineal stream bed distance of 7.66% of the en- tire Project and a difference in elevation of .22 of a'So:)t. No difficulty is anticipated in obtaining a license from the said Federal Power Conmiasion based upon Subdivision (i) of Section 10 of the Pules of Practice and Procedure established by the Federal Power Commission, which reads as follows: "In issuing licenses for a minor part only of a com- plete project, or for a complete project of not =ore than one hundred horsepower capacity, the commission may in its discretion waive such conditions, provisions, and require- ments of this act, except the license period of fifty years, as it may dee= to be to the public interest to waive under the circumstances: Provided, That the provisions hereof all -11 not apply to lards within Indian reservations." Obviously the government land proposed to be flooded is only a minor portion of the Major Project; therefore, the Federal Power Commission will unquestionably grant the licenae*.sincel the City of Lodi is the proprietor of property both up and doavnstream therefrom and consequently the said government land could be of no value or use to anyone other than to .the City of Lodi. X. Conclusion. From consideration of the foregoing recitation of the ma-jor facts bearing upon the reasonableness, desirability, feasibility and economic need of the proposed hydroelectric development of the City of Lodi and the resultant benefits to be derived by the City and the contiguous Rural District, it would appear that this Project is worthy of due consideration, not only as at constructive and progressive development in and for an already highly productive community, but as a nos', desirable and unusual enterprise of real - 21 - economic worth, one which entails the minima of risk and the naximua of safety in return or the improveaent investment and at the same time bring a present ::nd much needed future saving to the Cit .7 of Lodi and the Rural District Proposed to be served through the construction --nd operation of the City of ; odi Yoaelumne River Project i I 22 - r i I