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AGENDA TITLE: Funding Request from North San Joaquin Water Conservation District (NSJWCD)
MEETING DATE: December 15, 1999
PREPARED BY: Public Works Director
RECOMMENDED ACTION: That the City Council consider the request from the NSJWCD for financial
support for water rights activities.
BACKGROUND INFORMATION: Just prior to completion of the agenda for this meeting, the City
received the attached letter from the NSJWCD requesting financial
support for water rights activities. Due to time constraints, City staff
will present additional information and a recommendation to Council
at the December 15, 1999 meeting.
FUNDING: Water Fund
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Attachment
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Richard C. Prima, Jr.
Public Works Director
cc: Water/Wastewater Superintendent
NSJWCD, Fred Weybret
NSJWCD, Ed Steffani
APPROVED:
H. Dixon Flynn -- CityoManager
NSJ WCDFNDGREQST 12/08199
DIRECTORS
George A. Gillespie NORTH SAN J OAQ U I N WAT E R
Thomas Hoffman
JerryD. Mettler
Matthysys Van Gaalen CONSERVATION DISTRICT
Fred Weybret 221 W. Pine St., Lodi, CA 95240
December 8, 1999
City Council
City of Lodi
P.O. Box 3006
Lodi, CA 95241-1910
SUBJECT: North San Joaquin Water Conservation District Finances
GENERAL MANAGER
Edward M. Steffani
LEGAL COUNSEL
Stewart C. Adams, Jr.
I am writing as directed by North San Joaquin Water Conservation District (NSJWCD)
Board action of December 7, 1999.
As you know, NSJWCD includes most of the City of Lodi and approximately 50,000
acres of agricultural land to the east of the City. The primary function of the District is to
provide surface water from the Mokelumne River to correct the critical groundwater
overdraft. As you also know, the District's efforts have been limited by a budget
curtailed by Proposition 13. The current annual revenue of approximately $175,000 is
woefully inadequate, and the possibility for increasing revenue since the recent
Proposition 218 is slim.
An urgent matter is now before the District. The State Water Resources Control Board
(SWRCB) is scheduled to make the first so-called Bay/Delta decision on December 28cn
Part of the decision (see enclosed copies of pages 66 through 68 of proposed decision)
could severely restrict or eliminate the District's and the City's right to water from the
Mokelumne River. Special legal counsel and other expert help will be needed
immediately and during the next few months to fight this proposal. The District is without
funds to pay these costs.
It goes without saying that the City of Lodi benefits from the activities of the District.
Correction of the groundwater overdraft must be accomplished.
NSJWCD asks that the City help fund the District up to $100,000 annually, as special
needs may require. The District does not ask that this assistance be permanent, but
only until the District voters approve an increase in District revenue. We intend to
present such a request to the voters within the next four years.
We appreciate your understanding of our problem and hope that you will be able to help.
,1
jFed Weybret
President
North San Joaquin Water Conservation District
FW/ES/pmf
Enclosure
LCITYCOUNCIL
D * R * A * F * 1 December 2, 1999
Alternative 5 would be significantly greater than under the JSA, especially in the spring of
critically dry years. The USFWS did not, however, analyze the effects of these greater flow
releases on delta smelt. (R.T. pp. 3179-3180.)
It was argued that the JSA should not be approved until the flow requirements for achieving the
salmon doubling narrative objective are determined. Implementing the narrative objective for
salmon protection requires a long-term process. A period of actual operation meeting the
numerical objectives in the 1995 Bay -Delta Plan or the measures under the SJRAIVAMP,
coupled with adequate monitoring, is required before the SWRCB can determine whether
additional implementation measures are needed to meet this objective.
It was argued that the agreement should not be adopted until the flow requirements for meeting
water quality objectives in the interior of the southern Delta are determined. Additional
Mokelumne River flows, however, are unlikely to affect the salinity at these southern Delta
stations.
The North San Joaquin Water Conservation District (NSJWCD) argued that its water supply
should be protected from the effects of the MOU. (R.T. pp. 2988-2994.) When the SWRCB
approved EBMUD's water right application (for export of water) in SWRCB Decision 858, it
granted a junior permit to NSJWCD (an inbasin user) under a competing application.
(NSJWCD 2, pp. 3.) NSJWCD contends that the area -of -origin statutes were violated when
EBMUD was issued a permit. None of the area -of -origin statutes apply to EBMUD's water
rights, however, because EBMUD's water right is not based on a state -filed application under
Water Code section 10500 et seq., and EBMUD also is not subject to Water Code section 11460
et seq. The SWRCB granted a permit to EBMUD based on its municipal use being a higher
beneficial use of water than NSJW'CD's agricultural use, and found that there would be no
unappropriated water available to NSJWCD after EBMUD had completed putting its water to
beneficial use. The SWRCB issued a temporary permit to NSJWCD for water surplus to
EBMUD's needs.
The NSJWCD also makes the area -of -origin argument regarding the SWRCB's grant of permits
to the USBR for American River water, while denying a competing application of the NSJWCD.
D * R ° A * F + T December 2, 1999
(NSJWCD 2, p. 15.) In this case, both parties were exporters, so the area -of -origin statutes again
did not apply.
A portion of the overdrafted groundwater basin in NSJWCD's service area is within the legal
Delta. Thus, NSJWCD contends that this area is entitled to water, and should receive priority
over the SWP and the CVP for Delta water under the Delta Protection Statutes. The Delta
Protection Statutes, ho,.vever, protect existing water rights in the Delta. The NSJWCD currently
does not have water rights in the Delta. If the NSJWCD wishes to appropriate water from the
Delta, it will have to first file an application.
NSJWCD has water right permits to divert up to 80 cfs by direct diversion and 20 taf by storage
from the Mokelumne River between December 1 and July 1. The NSJWCD also contracts for
20 taf of surplus water from EBMUD to provide deliveries outside its diversion season.
The NSJWCD contends that it will bear the burden of EBMUD's increased fish flow releases
under the 1996 MOU because it will receive less surplus water from EBMUD. NSJWCD further
contends that EBMUD will suffer no water supply impacts as a result of the JSA. (NSJWCD 2,
pp. 12-13.)
One party argued that DWR cannot backstop the agreement without violating the Monterey
Agreement and the existing contracts. The Monterey Agreement is between the DWR and its
water supply contractors. The Monterey Agreement is not binding on the SWRCB and does not
limit the contents of a water right decision. Water supply contracts typically include provisions
recognizing that delivery is not required when water is not available due to applicable regulatory
requirements. (O'A'eil v. United States (1995) 50 F. 3d 677.) Even assuming the Monterey
Agreement could read as a guarantee by DWR to provide water notwithstanding limitations on
its water rights, any remedy for violation of the agreement would be between DWR and the
contractors.
WID has post -1914 water rights that are included in the Notice of Hearing for the Bay -Delta
Water Rights Hearing. These are Licenses 5945, 8214, and 8215 (Applications 5807, 10240, and
12648, respectively). WID also claims pre -1914 water rights. WID has an agreement with
67.
D ' R * A ' F * 1 December 2, 1999
EBMUD under which WID diverts 60 taf under its water right licenses and additional water
when available under its pre -1914 water rights. When inflow to Pardee Reservoir is less than
375 taf, WID's diversion is reduced to 39 taf. WID has passed a resolution stating that it will not
divert the expected flows below Woodbridge, which are identified in the JSA, if the StiVRCB
finds that the JSA flows are an adequate contribution to the Delta for the Mokelumne basin as a
whole. (WID 9; R.T. p. 2951.)
8.1.3 Sii'RCB Findings Regarding the Mokelumne Agreement
The flows under the JSA differ from the flows under Flow Alternatives 3 and 5. As USFWS
argued, Alternative 5 might provide more benefit for Delta fish than the other alternatives, but it
could result in more frequent consumptive use water shortages and more instances of elevated
water temperatures affecting fish. The SWRCB finds that the fish should be protected, but
consumptive uses nevertheless should be allowed to continue at a reasonable level. Excessive
releases for fish at some times could result in releases of water that is too warm for fish at other
times. The SWRCB finds that it would not be in the public interest to require more water from
the Mokelumne River system than will be provided under the JSA. Additional releases could
exacerbate the shortages experienced by NSJWCD. Further, any requirements imposed by the
SWRCB could be added to the JSA flows when the JSA flows are lower, but flows may not be
subtracted from the JSA when such flows are higher than the SWRCB alternatives. This could
result in greater releases than either the JSA or the SWRCB alternatives would require alone.
Accordingly, this decision establishes EBMUD's responsibility to help meet the Bay -Delta flow
dependent objectives consistently with the JSA provisions. Additionally, consistent with WID's
resolution, this decision establishes WID's responsibility by amending WID's water right
licenses to require that WID bypass the expected flows below Woodbridge, as defined in the
JSA. Unless it gives further notice, the SWRCB will not revisit the water rights on the
Mokelumne River in future phases of the Bay -Delta Water Rights Hearing.
The DWR has agreed to backstop a part of any incremental responsibility to provide water from
the Mokelumne River in excess of the JSA flows. Accordingly, this decision establishes a
responsibility for the DWR to backstop a share of any additional Mokelumne River
responsibility that the SWRCB determines after conducting further proceedings. The USBR
declined during the hearing to provide a backstop for Mokelumne River flows. The USBR,
6s.
CITY COUNCIL
STEPHEN). MANN, Mayor
ALAN S. NAKANISHI
Mayor Pro Tempore
SUSAN HITCHCOCK
KEITH LAND
PHILLIPA. PENNINO
CITY OF LODI
CITY HALL, 221 WEST PINE STREET
P.O. BOX 3006
LODI, CALIFORNIA 95241-1 91 0
(209) 333-6706
FAX (209) 333-6710
December 9, 1999
H. DIXON FLYNN
City Manager
ALICE M. REIMCHE
City Clerk
RANDALL A. HAYS
City Attorney
Mr. Fred Weybret, President
Mr. Ed Steffani, General Manager
North San Joaquin Water
North San Joaquin Water
Conservation District
Conservation District
c/o 125 North Church Street
c/o P. O. Box 3006
Lodi, CA 95240
Lodi, CA 95241-1910
SUBJECT: Funding Request from North San Joaquin Water Conservation District (NSJWCD)
Enclosed is a copy of background information on an item on the City Council agenda of
Wednesday, December 15, 1999. The meeting will be held at 7 p.m. in the
City Council Chamber, Carnegie Forum, 305 West Pine Street.
This item is on the regular calendar for Council discussion. You are welcome to attend.
If you wish to write to the City Council, please address your letter to City Council,
City of Lodi, P.O. Box 3006, Lodi, California, 95241-1910. Be sure to allow time for the
mail. Or, you may hand -deliver the letter to City Hall, 221 West Pine Street.
If you wish to address the Council at the Council Meeting, be sure to fill out a speaker's
card (available at the Carnegie Forum immediately prior to the start of the meeting) and
give it to the City Clerk. If you have any questions about communicating with the
Council, please contact Alice Reimche, City Clerk, at 333-6702.
If you have any questions about the item itself, please call me at 333-6759.
Richard C. Prima, Jr.
Public Works Director
RCPIIm
Enclosure
cc: City Clerk J
NNSJWCDFNDGREaST