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Email correspondence - Comment for Jan. 25, 2024 Plan for Water Workshop - Dianna Suarez

Dear NID Board and General Manager, I just read the beginning of the staff report for the 1-25-24 NID Board meeting and realized that the Board’s choices of options for further modeling were almost exclusively storage scenarios.  I find the lack of demand management modeling and analysis perplexing and believe that this lack of imagination and creativity will limit future successful outcomes. 

The NID Board meeting of 1-10-24, included Dustin Cooper telling the Board, “If unimpaired flow is the standard, I don’t know that you construct new above ground storage in California. You have unused storage with an unimpaired flow standard almost every year…..Above ground storage would never pencil out.”

Additionally, Dustin stated in the staff report, “It is unclear how the AHO would consider NID’s pending application for assignment of the state-filed Bear River water right, but the hearing process does vest the State Water Board with considerable discretion in deciding whether the assignment is in the public interest. Should NID abandon the petition for assignment, it is likely that legislation or other State Water Board fiat could extinguish state filed water rights.”

The Delta Water Quality Update poses a high risk for requiring higher instream unimpaired flow that would make surface storage “untenable”.  The State Water Board has overallocated existing water supply by 500% and is realizing the absurdity of future allocations.  So why are you modeling surface storage scenarios exclusively? 

I also noted that the terms alternative, option, and scenario are used interchangeably and cause confusion.  The Board is to give input on alternatives.  Then you say options were reviewed.  The spreadsheet identifies options. Consideration is given to determine options for additional modeling. But direction was given to model 3 of three scenarios.  Are you modeling options or scenarios or alternatives?  And then several options were identified for further consideration but not modeling.  Why?  These non-modeled options will be evaluated (instead of modeled?) to identify actual projects during the 4 master plans. 

Then the staff has recommendations to finalize analysis of storage options.  I thought they were scenarios.  Also, these modeled scenarios, that now are referred to as analyzed options, are actual projects.  This lacks clarity and transparency.

Reducing carryover storage was rejected but flexibility in carryover storage was not discussed, modeled, or analyzed. This option could have produced up to ¾ of the highest “unmet demand”.  This is a failure to follow NID’s strategic value of Innovation: Challenge the accepted to foster creative ideas and methods.

Canal automation was analyzed and will be addressed in the Raw Water Master Plan.  The estimated acre feet savings is 2% to 5% but the volume used for that calculation was 22 years old.  I have seen other figures up to 15% which could again offer a much more substantial acre feet savings.  What specific criteria was used to make the judgment?  Where are the specific criteria documented?

Metering raw water has been a popular idea for the public but NID sees lots of problems.  The statement was made that it may increase use or save 0% to 1,210 acre feet.  Where did these numbers come from?  The questionable analysis concludes “This item is not anticipated to reduce the overall demand significantly.”  How do you know?  There has been no analysis.  The item is approached as an all or nothing endeavor.  Why not give a few meters a try to see what someone uses compared to what they buy?  This may be valuable information. This is another failure to meet the moment and “increasing metering and embracing new technology is a District Strategic Priority.”

Meadow restoration and forest management will be analyzed in the Watershed Management Plan.  Maybe some actual data can be collected by then?

Canal encasement and lining will be analyzed in the RWMP.  The estimations are for significant savings and have been discussed for years. 

Sediment removal should be a given associated with reservoir maintenance, but NID says they are not legally liable for maintaining storage capacity.  Then why build reservoirs?  They will all eventually fill up with sediment.  Maybe dam removal should be considered, starting with Combie.  Commercial gravel removal will be addressed in the Operations Master Plan, but not modeled or analyzed.

Raising Rollins 50,000 acre feet is described as feasible, but no mention of the instream flow and water rights issue is included in the discussion.  Given these issues; why is it deemed feasible?  $290,202,500 is the estimated cost. Where did these numbers come from? Does the cost to each customer include interest charges?  This is over a 30-year timeline so interest would apply.  Saying it doesn’t include interest gives an incomplete analysis.  You do not list the true cost.

Raising Rollins 76,000 acre feet is deemed not feasible but raising Rollins 80,000 acre feet is; with a cost of almost a billion dollars not including interest.  Why?  This project is not needed in the next 50 years according to your “unmet demand”? Wouldn’t a cost of nearly 2 billion dollars including interest, and no need, make it not feasible? Same question with the 110,000 acre feet storage.  The cost you describe from 2017 (updated) does not seem to have increased much in 7 years, and why is it half the cost of a dam less than 50 feet higher?  Either way, the lack of need, the true cost in dollars, and the ecosystem degradation should render these scenarios not feasible.

What about the costs not mentioned in the analysis like replacing Dog Bar Bridge with a bridge like the Foresthill Bridge?  Buying the rest of the property? Demolishing houses, removing trees and infrastructure like septic systems all do not seem to be included.  Moving forward with surface water storage that has already been deemed “untenable” and not likely to be successful with necessary water rights for a dam you cannot afford and do not need is baffling and

presents as very irresponsible financial management, not to mention an appalling lack of “stewardship”.  Why not end this wasteful spending now?  Let’s finish this and move forward into the 21st century. 

Demand management is listed last on this matrix which does not seem to be much different from the previous version.  5 out of 8 possibilities are considered to move forward by TBD or Operations.  Demand management is the only “variable”

that NID can use to manipulate the relationship between supply and demand.  In an unpredictable and extreme climate scenario, Demand Management is the steering wheel, the accelerator, and the brake.  Demand management makes a seemingly impossible situation, manageable.

The most important element of demand management, Conservation, is totally blank.  This is a glaring inadequacy of your analysis.  Conservation is not even addressed.  This is an unacceptable omission and renders this process incomplete. Drought contingency is referred to in the “reservoir operations model”.  Education and conservation rebates are mentioned but not analyzed.  The analysis stops at the top of Demand Management, and it seems that no further thought was given because the District does not want to exercise demand management.  The rest of the ideas are not carried forward except reducing FERC required flows.  In all, NID dropped the ball on Demand Management.

Following the matrix, the modeling of the storage options and irrigation seasons doesn’t show much difference between the 50,000 acre feet raise and 110,000 acre feet dam.  Except there is a huge difference between the two options, or scenarios, or alternatives.  There is a community and a river ecosystem that hangs in the balance.  Restoration of this long-neglected watershed has been delayed because of a failure to come to a determinate decision on this issue.

At the end of today’s meeting, given the high costs and nonexistent need for the 110,000 and 80,000 acre feet storage scenarios; the high risk of unimpaired instream flows, and the probable withdrawal of outstanding appropriative water rights; if these options fail to be determined “not feasible”, then this is not a scientific process, this is a political process.


Thank you for your attention, Dianna Suarez


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