Reclamation Seeks Comments on Requirements for
Water-Related Contracting Activities
Send from firstname.lastname@example.org
of Klamath Bucket Brigade
From: email@example.com To: firstname.lastname@example.org, Aazhderian@sldmwa.org,
email@example.com, Sent: 10/24/2011 3:04:53 P.M. Pacific
Daylight Time Subj: BOR to Extend Comment Period for Reclamation
Dear Alliance Directors, Advisory Committee Members, and other
As reported to you last week, the Bureau of Reclamation is
seeking public comment on draft Reclamation Manual releases for
water-related contracting activities and water and related
resources feasibility studies. Mark Limbaugh and I on Friday
discussed this matter at length with Reclamation policy
officials in Denver, where we underscored our concern that many
in the Western water user community were not even aware that
this important process was underway. At a minimum, we asked for
a 30-day extension to the comment period, which was set to end
As a result of our call with Reclamation Denver, Mark was
informed earlier today that the comment period has been extended
until November 30 for all of the draft Directive and Standards
(D&S) for water contracting and feasibility studies. Reclamation
will be commencing an outreach effort at the upcoming National
Water Resources Association conference and in the Reclamation
Regions to get comments from water users in the next month.
Reclamation will issue a formal press release on this soon.
We will work with the Alliance Advisory Committee to prepared
coordinated and detailed comments on both of these issues.
I’ve attached additional, preliminary background information on
this matter below.
Please do not hesitate to contact me with any questions or
Best regards –
Family Farm Alliance
Reclamation is requesting public review and comment on draft
Directive and Standard (D&S), Water and Related Resources
Feasibility Studies (CMP 09-02). On approval, CMP 09-02 will be
published in the Reclamation Manual, which is used to clarify
program responsibilities and authorities and to document
Reclamation-wide methods of doing business. All requirements in
the Reclamation manual are mandatory for Reclamation staff. This
review period –which was set to expire October 21 - will provide
stakeholders the opportunity to offer input on the proposed
requirements prior to Reclamation finalizing and approving the
document. Of note, the new draft would provide three preferred
study alternatives – one from the Reclamation analysis, one
based on ecosystem benefits, and one based on the preference of
local stakeholders. There also appears to be a greater emphasis
on climate change considerations being taken into account, which
is consistent with the Administration’s priorities. Reference to
“net public benefits” is also included.
I strongly suggest that you have your management team and /or
your engineer take a look at this. Please let us know if we can
further advance or support any concerns that you have.
Reclamation is also proposing changes to its policy manual on a
topic which may bring back memories for some of you, who banded
together a few years ago to beat it back. Many 1902 Reclamation
Act projects, so-called single purpose irrigation projects, have
evolved to use water on residential lawns and gardens. Most
early project contracts are silent about these types of
“conversions.” In the past, this evolving use has not been
viewed as a “conversion” of Reclamation water, nor has it been
viewed as a “transfer,” so long as the water is used on the same
acreage and was not treated. Several times in the past, some
officials at Interior and Reclamation have attempted to change
that, and now, it looks like they are at it again.
Alliance Counsel Gary Sawyers recalls that, starting almost 20
years ago, Reclamation began inserting this same general concept
into renewed water service contracts for Central Valley Project
(CVP) users. Reclamation had originally wanted the threshold to
be 10 acres, and Gary and others finally negotiated them down to
5. Gary says CVP contractors do not like this, but have learned
to live with it. They (and others, elsewhere in the West) likely
would object loudly to a higher threshold, and would argue that
they have already dealt with this issue in their contracts. More
information on this topic is included below. Comments on this
proposal were originally due October 28.
Media Contact: Peter Soeth,
firstname.lastname@example.org , 303-445-3615
For Immediate Release: September 29, 2011
Reclamation Seeks Comments on Requirements for Water-Related
The Bureau of Reclamation is seeking public comment on draft
Reclamation Manual releases for water-related contracting
activities. These draft releases provide definitions of key
terms and revise existing definitions; restructure and clarify
Reclamation's water transfer and conversion policy; and
consolidate and set-out basic pricing requirements for
Specifically, the four draft releases available for review are:
· Draft RM Policy Water-Related Contract and Repayment General
Principles and Requirements (PEC P05). It revises an existing
policy by providing a number of definitions for terms of general
application for water-related contracting purposes. "Irrigation"
and "Municipal and Industrial" are defined in this draft Policy
to adjust and clarify the distinction between them. This ensures
that municipal and otherwise non-agricultural uses that involve
irrigation, such as golf courses, parks and lawns are properly
categorized as M&I uses.
· Draft RM D&S Water Rates and Pricing (PEC 05-01). This will
replace existing PEC 05-01 and addresses cost-recovery and
rate-setting requirements for water-related contracts.
· Draft RM Policy Transfers and Conversions of Project Water (PEC
09). This supersedes and replaces existing RM Policy Voluntary
Transfers of Project Water (WTR P02). In combination with the
new definitions in PEC P05 it realigns the water use categories,
defines the basic options and requirements for transfers and
conversions, and preserves Reclamation's support for beneficial
transfers and conversions.
· Draft RM D&S Conversions of Project Water from Irrigation Use
to Municipal and Industrial Use (PEC 09-01) provides additional
requirements for conversions of project water beyond the basic
requirements provided in PEC P09. It addresses the contractual
options and requirements for formalizing these conversions. It
also covers the option of using the Sale of Water for
Miscellaneous Purposes Act of 1920 for converting water from
irrigation-only projects to Municipal and Industrial uses.
The Reclamation Manual is used to establish Reclamation
requirements, assign program responsibility and establish and
document Reclamation methods of doing business.
These Reclamation Manual updates are available for review at:
Comments or questions may be directed to Owen Walker at email@example.com.
Comments must be received by Reclamation by 5 PM on October 28,
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Reclamation is the largest wholesale water supplier in the
United States, and the nation's second largest producer of
hydroelectric power. Its facilities also provide substantial
flood control, recreation, and fish and wildlife benefits. Visit
our website at http://www.usbr.gov.