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[Water_news] 5. DWR'S CALIFORNIA WATER NEWS: AGENCIES, PROGRAMS, PEOPLE - 9/20/07

Department of Water Resources

California Water News

A daily compilation of significant news articles and comment

 

September 20, 2007

 

5. Agencies, Programs, People

 

J STREET LEVEE REPAIR:

With timing becoming crucial, interim J levee repair moves ahead - Chico Enterprise Record

 

LEVEE MAINTENANCE FUNDING:

Levee tax seen in Yuba; Benefit assessment district under study - Marysville Appeal Democrat

 

PERIPHERAL CANAL:

Modesto Bee: Supervisors Oppose Peripheral Canal; Board Cites Increased Risk Of Flooding, Loss Of Agricultural Land - Modesto Bee

 

SPECIAL WATER SESSION:

Editorial: Water conservation should be first on California legislative agenda - San Jose Mercury News

 

Editorial: Water watch; Can Legislature and governor reach agreement on delta plan? - Santa Rosa Press Democrat

 

Letters to the Editor: Delta crisis calls for action now - Sacramento Bee

 

Laird named to statewide water issues - Salinas Californian

 

ACWA OUTREACH:

Water association launches education effort - Capitol Press

 

INTERIM MANAGER SELECTED:

Interim IID general manager picked - Imperial Valley Press

 

FLOOD BILL:

Editorial: Sign bill to fix flood district funding error - Fresno Bee

 

 

J STREET LEVEE REPAIR:

With timing becoming crucial, interim J levee repair moves ahead

Chico Enterprise Record – 9/19/07

By Barbara Arrigoni, staff writer

 

WILLOWS -- Just four little words. That's all it took.

 

"Get 'er done — now!" said Glenn County Board of Supervisors chairman Tom McGowan.

 

McGowan's words Tuesday meant a severely eroded section of the J levee on the Sacramento River will soon be fixed, putting an end to at least that worry during the upcoming winter.

 

"And get it done before it starts raining," McGowan added firmly.

 

The board's direction means county planning officials can go ahead with obtaining the necessary permits and a state grant to make the repair at River Mile 200 — a 400-foot-long area of the levee just north of the Gianella Bridge — that the river chewed at during heavy storms in the winter of 2005-06. The erosion there is so critical, the levee could fail in the next high-water event.

 

It's a temporary fix until federal officials get the nod and money to build a new setback levee to replace the century-old J levee.

 

Although county and state officials acknowledged months ago the River Mile 200 area was in critical need of repair, the Department of Water Resources recently noted it needs "urgent reinforcement."

 

That the repair needs to be done now was repeatedly emphasized during discussion between the supervisors, county planners, the state Department of Water Resources and The Nature Conservancy.

 

Deputy Planning Director Randy Murphy said the job will cover a total of 800 feet, which includes 200 feet on each side of the critical area, and will cost close to $300,000.

 

The county can obtain a non-competitive state grant, with the state covering 50 percent of the cost. For its half, the county will provide some materials, equipment and labor. Glenn-Colusa Irrigation District would provide 10,000 cubic yards of dirt at $10 per yard.

 

Planning Director Dan Obermeyer reminded supervisors that a year ago, the county was looking at a repair costing $2 million.

 

The county will still have to figure out how to come up with at least $30,000 for the project.

 

Obermeyer stressed that while environmental issues on the river are substantial, it's important to get this repair job done before the water starts to rise and before that critical area of the levee wears away.

 

The repair should last until the new levee is constructed in the next two to five years. Last May, federal officials said construction will likely begin sometime in 2009.

 

"This should give us a breather," Obermeyer said.

 

Another issue raised was liability, both of the repair project and the new levee. DWR representative Jeff Van Gilder said the state does not want to assume liability on the repair project, but is acting as a facilitator. However, Van Gilder's focus was on the critical condition of the repair site.

 

He said although two other areas on the levee are at risk, the project area "would be in peril in a bad flood event," and more at risk because it would be nearly inaccessible if failure occurs in a high-water event.

 

Obermeyer said the county's liability is only on the interim repair, and emphasized the job needs to be done now.

 

County Flood Control Manager Bob Johnson estimated it will take about a month to complete applications for Bureau of Reclamation and environmental permits, and grant papers.

 

He said the job will take about five weeks to complete, and he hopes work will start in November, if not sooner. Some work can be done in the rain, he added.

 

The supervisors will have to decide on final approval of the project once the paperwork is complete.

 

Both Johnson and Sheriff Larry Jones said they're pleased with the direction the board took, especially since they have been keeping watch on the levee condition since Dec. 31, 2005. #

http://www.chicoer.com//ci_6934420?IADID=Search-www.chicoer.com-www.chicoer.com

 

 

LEVEE MAINTENANCE FUNDING:

Levee tax seen in Yuba; Benefit assessment district under study

Marysville Appeal Democrat – 9/18/07

By Andrea Koskey, staff writer

 

The Three Rivers Levee Improvement Authority is considering a benefit assessment district for levee operation, maintenance and potential capital improvements in southern Yuba County.

TRLIA directors discussed the issue Tuesday and directed staff to continue researching the possibilities of an additional tax to help maintain the levees once work is completed.

“Standards are higher because (Reclamation District) 784 is going from a rural to an urban standard,” said TRLIA Executive Director Paul Brunner. “The benefit area is key in the type of assessment. We end up with different ranges. The benefit of a single family home in Linda is not going to be the same in Plumas Lake.”

Three Rivers is in line for $138.5 million in state bond monies to repair 13 miles of levees along the east bank of the Feather River.

To qualify for the funds, the authority has to provide the state with a funding plan to come up with a local share for capital improvements and operation and maintenance.

The assessment district would include housing in RD 784, as well as some residents in Linda and Olivehurst benefiting from the levee, but not being charged for that protection.

The assessment will also evaluate the need for capital improvements to levees in the future. Not having these funds, however, will not necessarily prevent the levees from being certified, Brunner said.

Brunner said it is too early in the process to discuss fiscal impacts for families because engineering documents are still being evaluated, but added the board wants to see information sooner rather than later.

“We are still looking at the drafts and working with numbers, which will include, some with operating and maintenance and some with capital improvements,” Brunner said. “No official numbers have been put out.”

RD 784 has an assessment in place from a 2000 election for levees along the Yuba River.

The measure for the new assessment could go before affected households in February or March 2008 during a special election.

“The rate structures (we have now) were based on the budget we had at the time,” Director Richard Webb said. “For a single family home, it’s about $60 a year, give or take $5.”

Webb said the rates are based on six assessed districts, which are based on the benefit and coverage of the levee. #

http://www.appeal-democrat.com/news/assessment_54232___article.html/levees_levee.html

 

 

PERIPHERAL CANAL:

Modesto Bee: Supervisors Oppose Peripheral Canal; Board Cites Increased Risk Of Flooding, Loss Of Agricultural Land

Modesto Bee – 9/18/07

By Inga Miller, staff writer

 

STOCKTON -- A canal between the Sacramento River and pumps near Tracy would damage the Sacramento-San Joaquin Delta, dry farms and provide a straw for Southern California to suck the region's water, San Joaquin County Supervisors said Tuesday.

 

The board voted unanimously to oppose the Peripheral Canal, which is among the options under study by state officials. Proponents say it would secure a safe water supply for communities south of Tracy in the event of an earthquake and protect the delta's fragile ecosystem.

 

But county officials argued the canal would do neither and instead invite a host of problems.

 

"As far as I'm concerned, Southern California's thirst shouldn't be quenched at San Joaquin County's expense," Supervisor Steve Gutierrez said before making a motion to oppose the canal. "There are other options for Southern California, and they just look at this as the easy straw."

 

Last month, a federal judge ordered steps be taken to protect delta smelt.

 

The threatened fish's habitat is destroyed by brackish water now pushed into the delta by powerful pumps in Tracy. They are used to take Sacramento River water from the delta to communities and farms to the south.

 

A state panel came up with two alternatives for moving water south; both include gates to control so-called seawater intrusion, levee improvements and environmental restoration. One of the plans also includes the Peripheral Canal. It would move the water directly to the pumps so it wouldn't go through the delta.

 

Gov. Schwarzenegger has praised the canal as a protective measure for ensuring safe drinking water should a massive flood or earthquake break levees in the delta and allow saltwater to flood in.

 

The irony is that the canal would be subject to an earthquake, too, said Thomas Flinn, the county's public works director.

 

Canal would be a temptation

 

Along one proposed alignment for the canal, 500 homes would stand to be affected by excavation, according to C. Mel Lytle, water resources coordinator for the county.

 

"We don't see there being any true benefit to the county, and the impacts are numerous," he said.

 

Among them are increased risk of flooding, seepage of water from the canal onto adjoining land, agricultural land lost and the potential for losing water rights.

 

Then "there is still the philosophical problem that we still need to keep enough water in the delta to keep the delta healthy," Flinn said. "And in dry times, it would be very tempting for people to take all the water they can through the canal, and then the delta would become very saline."

 

The temptation for the state to divert water south and leave area farmers in the lurch became all too apparent during the past two droughts, in 1976-1977 and in 1991-1992, when the state suspended water rights, said Dante John Nomellini, who represents the Central Delta Water Agency.

 

"It boils down to the emergency power of government," he told supervisors.

 

"They sus-pended all water rights and contracts and basically instituted martial law. The conduct of the state in the past has demonstrated they have not acted in a way that suggests they would act in good faith in the future.

 

The delta smelt ... is an example of the operators running rough-shod over what is clearly known to be a very sensitive part of the delta."

 

The Metropolitan Water District of Southern California supports the canal.

 

So does the California Partnership for the San Joaquin Valley, a panel created by Schwarzenegger to make recommendations for improving the region's economy and quality of life. It sent a letter signed by Kern County Supervisor Ray Watson seeking San Joaquin County's support.

 

"As a member, we need to send a clear message that we have some concerns regarding the request," Supervisor Victor Mow said. "Otherwise, we are going to get run over by a train, and in that context, I don't know where Stanislaus County is on this issue. And we probably need to talk to Contra Costa County and relay our concerns and our positions."

 

Board members decided to ask San Joaquin County's cities to endorse the position, and the board plans to send a letter to the California Partnership stating the county's position.

 

San Joaquin County has only a limited voice on the partnership, whose other communities are to the south, Supervisor Leroy Ornellas said. "The southern part of the valley has a tremendous amount of influence and it makes a lot of noise, so we need to do as much as we can from this county," he said. #

http://www.modbee.com/local/story/71525.html

 

 

SPECIAL WATER SESSION:

Editorial: Water conservation should be first on California legislative agenda

San Jose Mercury News – 9/19/07

 

The governor and lawmakers are in a special legislative session, attempting to craft a solution to California's water woes. But their focus on multibillion-dollar bond proposals that would pay for dams, reservoirs, canals and other expensive water works shouldn't be getting the most attention.

 

Instead, policy-makers should be requiring more conservation and efficient water use. Reducing wasteful water use offers the most cost-effective way of ensuring California's fragile water supply.

 

Gov. Arnold Schwarzenegger and lawmakers need to make sure that water agencies, consumers, businesses and farmers have the proper system of mandates, incentives and pricing in place so that California can continue making strides in efficient water use.

 

Efficiency gains already have been significant. California's total water use is down sharply from a peak in 1980 even as the state's economy and population have grown sharply. The state's per capita consumption of water has stayed at roughly 1,100 gallons a day over the past decade, down about 40 percent from 1970, estimates the Pacific Research Institute.

 

But more needs to be done.

 

The greatest potential for additional efficiencies is among California's urban residents. More homeowners need to install low-flow shower heads and toilets, efficient washing machines, and drought-tolerant landscaping. Businesses like biotech companies or car washes need to speed up adoption of newer water-efficient practices and recycling. And policy-makers need to put in place appropriate pricing and incentives that promote conservation.

 

Agriculture, which uses 80 percent of the state's water, also needs to accelerate changes. Farmers should speed up the installation of drip systems, sprinklers, sensors and other technologies. Today, only about 35 percent of the state's farm land uses drip irrigation. But with about 50 percent of the land still on wasteful flood irrigation systems, there's a lot more room for improvement. Farmers, whose water often comes at cheap, subsidized prices, also need to continue shifting away from water-intensive crops such as cotton and alfalfa and toward more water-efficient, higher-value fruits and vegetables.

 

Improving the management of groundwater and increased use of recycled water also should be encouraged.

 

Conservation and more efficient water use may not solve the problem. But Gov. Arnold Schwarzenegger and Senate President Pro Tem Don Perata, D-Oakland, are working primarily on bond proposals for 2008 - $9 billion and $5.4 billion respectively - that call for building more storage and delivery systems.

 

That might be needed, but policy-makers should first look to using some of the $10 billion in water-related bonds voters already passed last year.

 

Both the governor and lawmakers should resist the urge to simply throw a lot of concrete at the water problem, with taxpayers picking up the tab. Building infrastructure will always look like a bolder solution compared with conservation and efficiency.

 

But sensible, achievable and less expensive strategies should not be shortchanged. #

http://www.mercurynews.com/opinion/ci_6935052

 

 

Editorial: Water watch; Can Legislature and governor reach agreement on delta plan?

Santa Rosa Press Democrat – 9/19/07

 

The goings-on of the state Legislature are about as fascinating as "Full House" reruns -- so it's no surprise that most Californians aren't paying attention to the special session that's currently under way.

ADVERTISEMENT


Too bad. Because what happens during the next few weeks could bring major changes to the state.

Gov. Arnold Schwarzenegger called the special session so lawmakers could address two issues they failed to resolve before adjourning last week: health care and water. Because of an Aug. 31 court decision, water is receiving lawmakers' immediate attention.

A federal judge ruled late last month that pumping from the Sacramento-San Joaquin Delta may have to be reduced by as much as 37 percent in order to protect endangered fish. In addition, recent studies have pointed out the fragility of the aging delta system.

There is general agreement that the system needs fixing. The big questions are how to do it and whether voters will be willing to pay for it.

Schwarzenegger and Senate leader Don Perata, D-Oakland, have offered two different approaches, and Assembly Democrats are expected to propose a third.

The governor's proposal calls for a $5.9 billion bond to construct two new dams, a delta canal and conservation programs. Senate Democrats advocate a slightly smaller bond ($5.4 billion), with the money being spent on delta improvements and water supply reliability projects that would require local funding matches.

Battles will likely focus on (1) a canal (the words "peripheral canal" still carry heavy emotional baggage for many Californians, (2) dams (while more storage is needed, voters haven't been receptive to building new reservoirs), (3) spending in areas outside the delta region (other regions also need help with water systems) and (4) resource protection (whether the plans will protect the delta smelt and other endangered fish).

Stay tuned. What happens in the Legislature may not be prime time, but it could affect the water supply of millions of Californians and thousands of acres of farm land.  #
http://www1.pressdemocrat.com/article/20070919/NEWS/709190326/1043/OPINION01

 

 

Letters to the Editor: Delta crisis calls for action now

Sacramento Bee – 9/19/07

By Timothy Quinn, Sacramento, Executive Director, Association of California Water Agencies

 

Re "Whoa! Stop the rush on governor's water plans," editorial, Sept. 14: Let me see if I can put the current water crisis into perspective. A federal judge just reduced water supplies conveyed through the Delta by one-third. California's hard-won voluntary water market is crippled because the Delta is broken.

 

Water storage projects in Southern California -- funded by public dollars and designed to help the Delta environment -- are rendered ineffective because those projects need water conveyed through the Delta to be replenished. Economic repercussions are growing every day in both the agricultural and urban economy.

 

And the best advice The Bee can give to readers is "Whoa!" on an action plan to fix all this? This "wait and see" approach is the kind of logic that got us into this mess in the first place.

 

Today, we are operating the state's water system with infrastructure that is utterly incapable of protecting both our environment and our economy. We must invest in a system that can do both. That will require a comprehensive plan with improvements in Delta conveyance and additional groundwater and surface storage.

 

The governor and our legislative leaders were right to call a special session. We need action and we need it now. #

http://www.sacbee.com/110/story/386544.html

 

 

Laird named to statewide water issues

Salinas Californian – 9/19/07

 

Assembly Speaker Núñez has named Assemblymember John Laird (D-Santa Cruz) to lead the Assembly working group focused on the special session on statewide water issues. The special session was called for by the governor.

 

In his role in the working group, Assemblymember Laird is expected to lead discussions between the governor, the Senate and the Assembly as they craft legislation to address various water issues facing California. In addition to Mr. Laird, members of the Assembly working group include Lois Wolk (D-Davis), Juan Arambula (D-Fresno), Mary Salas (D-Chula Vista), Jared Huffman (D-San Rafael), Paul Krekorian (D-Burbank), Mike Feuer (D-Los Angeles) and Mike Eng (D-Monterey Park).

The working group is expected to begin meeting next week.

A long-time leader on water issues, Laird authored a number of bills in 2007 related to flood control and water conservation that have been sent to the governor for his approval, including AB 156 (flood control planning), AB 715 (high-efficiency toilets), AB 1404 (urban and agricultural water use measurement), and AB 1420 (urban water conservation).

In 2006, Mr. Laird authored three bills on flood control and water conservation that were signed by the governor, including AB 984 (eradication of water-consuming, non-native Tamarisk along the Colorado River), AB 1881 (urban water conservation) and AB 2348 (Pajaro River levee repair).

In addition to serving as chair of the Assembly Budget Committee, he is a member of the Assembly Natural Resources Committee. In his first term, Laird served as chair of the Assembly Select Committee on California Water Needs and Climate Change.  #

http://thecalifornian.com/apps/pbcs.dll/article?AID=/20070918/NEWS01/70918010/1002

 

 

ACWA OUTREACH:

Water association launches education effort

Capitol Press – 9/18/07

By Elizabeth Larsen, staff writer

 

A group representing 450 state water agencies has launched a campaign to raise public awareness of the critical water issues facing the state.

The Association of California Water Agencies last week announced its statewide public education program, entitled "California's Water: A Crisis We Can't Ignore."

The association issued a statement in which it explained that the campaign is intended to educate Californians about critical challenges now confronting the state's water supply and delivery system.

Those challenges include the Sacramento-San Joaquin River Delta, where a recent court decision is expected to result in a reduction of about one-third of the water exported from the estuary.

"We are facing some of the most significant challenges to our water system in a half-century, yet the public is largely unaware of it," Timothy Quinn, executive director of the Association of California Water Agencies, said in a written statement. "This crisis isn't coming; it is here and now."

Jennifer Persike, spokesperson for the Association of California Water Agencies, said the campaign includes television, radio, print and Internet advertising aimed at all areas of California, from urban to rural, from county and city elected officials to citizens. Ads and fact sheets are offered in both English and Spanish.

Persike said the plan was well under way since before the court-ordered reduction in exports was announced late last month, although they knew the judge was to consider protections for the threatened delta smelt.

The fundraising effort to pay for the campaign kicked into full swing in August, she said. The first week of August the agency sent out letters to its public agency water members asking for voluntary support. That is the only group the association is tapping for funds, she added.

"We're still in the fundraising mode. We need more dollars to fully flesh out the program."

Already, they've been able to raise a substantial amount of money to fund the multimillion-dollar campaign, which will run through the end of the year, Persike said.

The campaign's television ad launched Monday, and Persike said it has had received an excellent response.

The association has conducted public education efforts before, said Persike, "but never at this level."

She credited Gov. Arnold Schwarzenegger for being ahead of the curve when it comes to understanding water issues. Schwarzenegger and U.S. Sen. Dianne Feinstein convened a summit in August to discuss the Bay Delta and other critical state water issues.

But the "missing piece," she said, has been the public's knowledge of just how critical water supply is becoming. That's largely because the water agencies the association represents have continued to do their jobs, so when water users turn on the tap, the water has remained flowing.

Persike said state water agencies don't want to find themselves in the same situation the energy industry did in recent years. In California, the strained energy supply led to rolling blackouts.

It's critical to ensure the public understands the issues, added Persike.

In the meantime, Schwarzenegger has called a special summer legislative session to deal with certain key issues, among them water. The session started Monday, and Persike said the association is keeping an eye on developments. #

http://www.capitalpress.info/main.asp?SectionID=94&SubSectionID=801&ArticleID=35365&TM=8906.402

 

 

INTERIM MANAGER SELECTED:

Interim IID general manager picked

Imperial Valley Press – 9/19/07

By Darren Simon, staff writer

 

After just more than a year with the Imperial Irrigation District as its information technology chief, Mike Campbell has quickly risen through the ranks — at least when it comes to interim roles.

He recently was named interim chief operating officer by Elston Grubaugh, who then was serving as acting general manager but as of last week retired from the district.

In Grubaugh’s place, Campbell on Tuesday was officially named interim general manager — a role that places him at the district’s helm possibly until the year’s end if that’s how long it takes the district to name a permanent general manager.

By a unanimous vote, the board placed Campbell in the interim general manager position.

“The board’s action today to clarify my role as interim general manager for the IID is a positive one for the organization,” Campbell said.

 

 

He added as the district considers structural and organizational changes to ensure increased efficiency and better management, his service as interim general manager will enable such changes to move forward.

Campbell takes the reins of the district at a time of turmoil in upper management, where one general manager was fired, an acting general manager unexpectedly retired and the search continues for an energy manager.

In July the district board, by a 4-1 vote, fired then-general manager Charles Hosken after he had served two years of a three-year contract.

The board has never given specific reasons as to his termination, but board members have said change in the district was not occurring fast enough.

His firing also followed an energy trading scandal within the district where millions of dollars in public funds were spent in violation of IID trading policies.

While the violations occurred in 2005 before Hosken was general manager, impacts from those violations, namely increased charges to power customers, occurred during his tenure.

In the wake of his firing, Grubaugh was named acting general manager, but he suddenly retired from the district last week, giving the board just one day’s notice of his departure.

While he hasn’t spoken specifically about his reasons for retiring, he took that step after he found his steps to reorganize how the district oversees and reviews major projects questioned by at least one board member.

As Campbell begins his tenure as interim general manager, his role will be to keep the lights on and the water flowing as the district steers through weighty issues in coming weeks and months, including one of the larger power agreements IID has ever considered and how to split a shrinking amount of water between farmers, cities and industry.

“I think he’ll do fine in overseeing the day-to-day operations,” IID Director Mike Abatti said of Campbell’s ability to lead the district.

He added the board is moving as quickly as it can to find a permanent general manager.

Director John Pierre Menvielle also spoke of Campbell’s ability to lead the district, stating he has served in leadership roles in corporations larger than the district.

In other actions Tuesday, the district named IID spokesman Kevin Kelley to serve as interim liaison to the IID board on governance issues.

The board recently approved a new governance policy that dictates the board’s role, the role of the general manager and the steps needed to ensure proper oversight and communication occurs throughout the district.

As the board’s liaison, Kelley will help guide the board as it puts its new governance policies into practice. #

http://www.ivpressonline.com/articles/2007/09/19/news/news02.txt

 

 

FLOOD BILL:

Editorial: Sign bill to fix flood district funding error

Fresno Bee – 9/19/07

 

An error in calculating revenues has cost the Fresno Metropolitan Flood Control District more than $5.5 million since 1992.

 

There's a bill on the governor's desk that would stanch that bleeding, and we urge him to sign it.

 

The problem began years ago when district revenue was overestimated. Like all local government agencies, the flood control district is required to shift a portion of its property tax revenues into what's called the Educational Revenue Augmentation Fund, or ERAF.

 

ERAF was set up to support schools in the wake of huge state budget deficits in the early 1990s. To fill a school funding gap, the state shifted some $4 billion annually from other local agencies.

 

But the overcalculation of flood control district revenue has meant that a larger share of its annual property tax revenues was shifted to schools than the law requires.

 

That has cost the district dearly. A number of important projects have been delayed or deferred, including the completion of the Fancher Creek Detention Basin, landscaping of flood control basins and other capital improvements.

 

Assembly Bill 263, by Assembly Member Juan Arambula, D-Fresno, would correct the mistake. The district wouldn't get back any of the money it has already lost, but at least it wouldn't lose any more than required from this point on.

 

The Fresno Metropolitan Flood Control District has long been one of the more effective local government agencies hereabouts. It serves a wide area between the San Joaquin and Kings rivers that is home to about 700,000 people.

 

The district doesn't just do flood control, though that's its principal task. It also provides urban drainage and groundwater management, and offers recreation and open space that's vital in urban areas.

 

Giving the district the full funding it deserves seems obvious. We hope the governor agrees, and signs AB 263.  #

DWR's California Water News is distributed to California Department of Water Resources management and staff, for information purposes, by the DWR Public Affairs Office. For reader's services, including new subscriptions, temporary cancellations and address changes, please use the online page: http://listhost1.water.ca.gov/mailman/listinfo/water_news. DWR operates and maintains the State Water Project, provides dam safety and flood control and inspection services, assists local water districts in water management and water conservation planning, and plans for future statewide water needs. Inclusion of materials is not to be construed as an endorsement of any programs, projects, or viewpoints by the Department or the State of California.

 

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