Calaveras Community Planning Coaliton Comments on Water Plan

On April 18, 2014, CAP’s Tom Infusino submitted, on behalf of the Calaveras Community Planning Coalition, comments on DWR’s draft review of the Final MAC IRWMP Update submitted by UMRWA.  In addition to these comments,  a disk of support materials was added for the record.  Most of these documents accompanied the October 17, 2012 comments on the Draft MAC IRWMP, but were excluded from the plan’s background materials provided to DWR.

“We at the CPC respectfully disagree with your draft assessment of the adequacy of the MAC IRWMP.  In summary, the MAC IRWMP is substandard in the following ways.

1) The Governance Section of the plan fails to disclose the imbalance of power and lack of collaboration among stakeholders.

2) The Regional Description in the plan provides inaccurate water demand information, and misrepresents regional conflicts.

3) The Goals, Objectives, and Performance Measures Section of the plan misrepresents MAC IRWMP process as a collaborative one.\

4) The Project Review Section of the plan provides an inaccurate description of the project review process, presents a project-proponent-biased evaluation of the projects, and submits a list of projects that fails to implement many provisions of the plan.

5) The Data Management Section of the plan does not identify obvious data gaps, and does not recommend ways to fill those gaps; and thus state and local decision-makers will remain without the critical information they need for rational water planning and infrastructure finance.

6) The Financing section discloses neither O&M costs, nor the percentage of funding from local sources, thereby depriving both state decision- makers and local ratepayers of the critical information they need to assess the desirability and financial feasibility of the proposed projects.

7) The Technical Analysis Section fails to disclose uncertainty regarding data used in the plan, and does not bridge data gaps as part of project or plan implementation.

8) The Water and Land Use coordination sections are tainted by the failure to disclose the unresolved controversy regarding the poor quality of land use and water demand data, and by the erosion of mechanisms to coordinate land use and water planning.

9) The Stakeholder Section does not admit that many important stakeholders did not participate in the process, as there were only two inconvenient methods of participation.

We at the CPC identified these flaws during the MAC IRWMP process, and have repeatedly presented options to improve the plan to the RPC.  However, the agency-dominated RPC has indicated that it will not make any adjustments to correct alleged flaws in the plan, unless DWR directs them to do so.  Thus, your accurate review of the MAC IRWMP is our last administrative hope of correcting the serious flaws in this plan.

Read Full Report Here