MWD ICS Table of Contents

Table of Contents

DOCUMENTS RELATED TO THE CREATION, DELIVERY, AND ACCOUNTING OF THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S (MWD) INTENTIONALLY CREATED SURPLUS (ICS)

1. MWD’s Extraordinary Conservation ICS Plan of Creation for Calendar Year 2019.

2. Reclamation’s letter to MWD dated August 13, 2019, approving MWD’s Extraordinary Conservation ICS Plan of Creation for Calendar Year 2019.

3. Calendar Year 2019 Fallowed Land Verification Report PVID/MWD Forbearance and Fallowing Program dated May 7, 2020.

4. Reclamation’s letter to MWD dated May 15, 2020, verifying the amount of Extraordinary Conservation ICS created by MWD in Calendar Year 2018.

THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA

Office of the General Manager

June 17, 2019

Mr. Steven C. Hvinden Office Chief Boulder Canyon Operations Office U.S. Bureau of Reclamation P.O. Box 61470 Boulder City, NV 89006-1470

Dear Mr. Hvinden:

Metropolitan's 2019 Plan for the Creation of Extraordinary Conservation Intentionally Created Surplus

In accordance with Section 3.B.1 of the Interim Guidelines for the Operation of Lake Powell and Lake Mead, enclosed is The Metropolitan Water District of Southern California's (Metropolitan) Plan for the Creation of Extraordinary Conservation Intentionally Created Surplus (ICS) During Calendar Year 2019 (Plan). On January 2, 2019, during negotiations of the Colorado River Basin States' (Basin States) Drought Contingency Plan (DCP), Metropolitan submitted a preliminary 2019 Plan.

With the execution of the DCP on May 20, and pursuant to the U.S. Bureau of Reclamation's (Reclamation) request, this letter rescinds and replaces the previously submitted preliminary 2019 Plan. The Plan contains new extraordinary conservation activities authorized by the DCP using Reclamation's new format.

Metropolitan is seeking approval to create up to 450,000 acre-feet of Extraordinary Conservation Intentionally Created Surplus during 2019, and this Plan would maximize California's available ICS storage. If there is unused ICS accumulation space from the other Lower Basin States, Metropolitan may also use that available capacity under the storage limits and sharing provisions of the DCP. Metropolitan's Plan demonstrates how all requirements of the Guidelines will be met in the creation of Extraordinary Conservation Intentionally Created Surplus.

700 N. Alameda Street, Los Angeles, California 90012 • Mailing Address: Box 54153, Los Angeles, California 90054·0153 • Telephone (213) 217·6000 THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA

Mr. Steven C. Hvinden Page 2 June 17, 2019

Metropolitan looks forward to the Secretary of the Interior's review and approval of the plan in consultation with the Basin States. Should you have any questions regarding our Plan, please contact me at (213) 217-6520.

Very truly yours,

William Hasencamp Manager of Colorado River Resources

TJR: rh

Enclosure The Metropolitan Water District of Southern California

Revised Plan for the Creation of Extraordinary Conservation Intentionally Created Surplus During Calendar Year 2019

Introduction

This revised plan for the creation of Extraordinary Conservation Intentionally Created Surplus (ICS) has been prepared pursuant to the specifications outlined in Section 3.B.1 on page 40 of the Record of Decision: Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations for Lake Powell and Lake Mead signed by the Secretary of the Interior (Secretary) on December 13, 2007. Eight separate activities are described in this plan, the first four of which are incorporated as an exhibit to the December 13, 2007, Lower Colorado River Basin Intentionally Created Surplus Forbearance Agreement (Forbearance Agreement) among the Arizona Department of Water Resources, the Palo Verde Irrigation District, the Imperial Irrigation District, the City of Needles, the Coachella Valley Water District, The Metropolitan Water District of Southern California (Metropolitan), the Southern Nevada Water Authority, and the Colorado River Commission of Nevada, and the remaining four are incorporated through the terms of the March 20, 2019 Lower Basin Drought Contingency Operations Plan Agreement (LBOps), Exhibit 1, Section IV.E.2 of said agreement. The potential yields of these extraordinary conservation activities for calendar year 2019 are approximately as follows:

Estimated Yield (acre-feet)

Activity 1: Palo Verde Irrigation District Forbearance and Fallowing Program 49,301a

Activity 2: Imperial Irrigation District Water Conservation Program 110,000b

Activity 3: Water Supply from Desalination 129,874c

Activity 4: Water Supply from Lower Colorado Water Supply Project 10,000d

Activity 5: Landscape Transformation Program 34,125e

Activity 6 Indoor Water Conservation Devices 91,383f

Local Resources Program Additional Groundwater Recovery Activity 7: 11,875g Projects

Activity 8: Local Resources Program Recycling Projects 311,653h

Total 748,211

-1- a Amount may be reduced depending upon any participating landowner’s request to reduce the area of land to be fallowed, which request may be approved or denied by Metropolitan, and the amount of water determined to be saved by the Program. b Amount may be reduced depending upon Coachella Valley Water District’s use of up to 20,000 acre-feet. c Amount may be reduced depending on actual amount of desalted water production from desalination projects within Metropolitan’s service area. d Amount may be reduced depending on actual pumping volume and the amount of water used by other Lower Colorado Water Supply Project contractors. e Amount may be reduced depending on the amount of water conserved by turf removal in Metropolitan’s service area. fAmount may be reduced depending on the actual amount of water conserved indoor in Metropolitan’s service area gAmount may be reduced depending on actual amount of water groundwater recovered within Metropolitan’s service area that is not already covered by Activity 3. h Amount may be reduced depending on the amount of water recycled in Metropolitan’s service area.

From the yields of these extraordinary conservation activities, Metropolitan plans to create a total of up to 450,000 acre-feet of Extraordinary Conservation ICS during 2019, should an increase in additional creation limit be available in 2019 and the Secretary authorize Metropolitan to create additional Extraordinary Conservation ICS through application of Section IV.B. of Exhibit 1 to the LBOps.

Documentation that the ICS Plan of Creation is in Conformance with any State or Agency Agreements regarding ICS

While the amount of Extraordinary Conservation ICS that Metropolitan plans to create is above the limits of Extraordinary Conservation ICS that can be created and accumulated in Lake Mead by Metropolitan under the December 13, 2007, California Agreement for the Creation and Delivery of Extraordinary Conservation Intentionally Created Surplus1 as amended, Section IV.B of Exhibit 1 to the LBOps states that “If one but not all of the Lower Division States reaches its annual Extraordinary Conservation ICS creation limit, and if there remains a desire to create additional amounts of Extraordinary Conservation ICS, the Secretary…may authorize additional Extraordinary Conservation ICS creations within the total annual limitation set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines.” The total annual limitation set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines is 625,000 acre-feet, and the amount of Extraordinary Conservation ICS that Metropolitan plans to create is within that limit. Absent the creation of Extraordinary Conservation ICS, this water would otherwise be beneficially used by Metropolitan through diversion into the Colorado River Aqueduct. The amount of Extraordinary Conservation ICS that Metropolitan may create is limited to the amount of Colorado River water that, if added to its consumptive use, would not result in an inadvertent overrun pursuant to the Bureau of Reclamation’s October 10, 2003, Inadvertent Overrun and Payback Policy. Reclamation has previously received a copy of the December 13, 2007, Agreement as amended which documents the terms and conditions for the creation and delivery of Extraordinary Conservation ICS by the California water agencies which are parties to the Agreement.

1 The parties to the California Agreement for the Creation and Delivery of Extraordinary Conservation Intentionally Created Surplus as amended are Palo Verde Irrigation District, Imperial Irrigation District, Coachella Valley Water District, the City of Needles, and Metropolitan.

-2- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 1

Exhibit 1 The Metropolitan Water District of Southern California Palo Verde Irrigation District Forbearance and Fallowing Program

ICS Category: Extraordinary conservation (EC) res Subcategory: Land fallowing

Term: August 18, 2004 - July 31, 2040. Metropolitan has issued a Fallowing Call for 10,379 acres for the period from August 1, 2018 to July 31, 2019. Metropolitan made no additional fallowing call for the period from August 1, 2019 to July 31, 2020. Therefore, the fallowing call for calendar year 2019 is 10,379 acres.

Project Description: Under the August 18, 2004, Forbearance and Fallowing Program Agreement with the Palo Verde Irrigation District (PVID) and landowner agreements for fallowing in PVID, Metropolitan pays landowners within the Palo Verde Valley to annually fallow a portion of their land, foregoing the planting and irrigation of crops, allowing PVID to forbear use of water on lands that historically were and otherwise would be irrigated, increasing the amount of water available to Metropolitan.

The volume of water that becomes available to Metropolitan is governed by the October 10, 2003, Quantification Settlement Agreement1 (QSA) and the October 10, 2003, Colorado River Water Delivery Agreement.2 Under these agreements: • Metropolitan must reduce its consumptive use of Colorado River water by that volume of consumptive use by PVID and holders of Priority 23 that is greater than 420,000 AF in a calendar year, or • Metropolitan may increase its consumptive use of Colorado River water by that volume of consumptive use by PVID and holders of Priority 2 that is less than 420,000 AF in a calendar year.

In both cases, each acre-foot of reduced consumptive use by PVID is an additional AF that becomes available to Metropolitan.

Palo Verde Valley landowners voluntarily decided in 2004 whether to participate in the 35-year Program, with those participants agreeing to stop irrigating from 9 to 35 percent of their land in any year at Metropolitan's request. Upon one-year notice, Metropolitan has the option to change the percentage of land fallowed, with an increase in the percentage effective for a two-year period. The land taken out of agricultural production is maintained and rotated once every one to five years. The maximum amount of farmland taken out of production at any one time is

1 The parties to the Quantification Settlement Agreement are Imperial Irrigation District, Coachella Valley Water District, and Metropolitan. 2 The parties to the Colorado River Water Delivery Agreement are the United States, Imperial Irrigation District, Coachella Valley Water District, Metropolitan, and the San Diego County Water Authority. 3 The Yuma Project Reservation Division holds California's Priority 2.

-1- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 1

25,947 acres; however, fallowing in excess of 23,508 acres is limited to a total of ten years under the 35-year Program. The landowner is responsible for payment of taxes, PVID water tolls, vegetation abatement, dust control and all other costs related to the fallowed lands. Parcels to be fallowed must be at least 5 acres. Through October 2018, Metropolitan has paid a total of $257 million in Program costs.

Annual JCS Creation Amount: The projected volume of conservation from land fallowing during calendar year 2019 is 49,301 acre-feet based on the average amount of water used for irrigation in the Palo Verde Valley from 1998 to 2002. The monthly tabulation of this projected savings is as follows:

Monthly Land to be Reduced Irrigation Month Fallowed Consumptive Use Use Factor* (acres) (acre-feet)** (acre-feet/acre) January 0.036585 10,379 380 February 0.202073 10,379 2,097 March 0.324799 10,379 3,371 April 0.535759 10,379 5,561 May 0.663143 10,379 6,883 June 0.732893 10,379 7,607 July 0.761558 10,379 7,904 August 0.658148 10,379 6,831 September 0.366795 10,379 3,807 October 0.251584 10,379 2,611 November 0.107865 10,379 1,120 December 0.108799 10,379 1,129 Total 49,301 *Monthly portion of 4.75 acre-feet per acre annual use. **Volumes rounded to the nearest acre-foot.

Absent this proposed creation of EC ICS, an amount of water equal to the proposed EC ICS would have been imported from the Colorado River.

Quantification Methodology: Although it is evident that water is conserved through land fallowing, it is not possible to measure the exact amount of conservation because the types and acreage of crops that would have been grown on the fallowed lands absent the fallowing program are unknown. Therefore, the projected volume of conservation from land fallowing during calendar year 2019 (49,301 acre-feet) was quantified by multiplying monthly irrigation use factors ( column 2 of the table above) by the amount of land to be fallowed (column 3 of the table above) for each month, and then summing these twelve products.

The monthly irrigation use factors represent average monthly per-acre irrigation water use in the PVID service area for the five-year period 1998 through 2002. A statistical inference analysis

-2- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 1

(two sample t-test) was performed to determine if the means for the 1998-2002 and 2006-2017 irrigation water use factors come from the same population. While the 2006-2017 period is more recent, the difference between the average water use factor from the 2006-2017 population and the 1998-2002 population is not large enough to be statistically significant. Therefore, use of data from the 1998-2002 period was statistically justified. Additionally, MWD believes data from the 1998-2002 period best reflect the agronomic, land ownership, weather, water use, and market conditions prevailing in the PVID service area during calendar year 2019.

Verification Methodology: Upon designation of fallowed acreage, a Metropolitan representative visits the field on the date when fallowing is to commence and verifies that fallowing conditions have been met. The same procedure is followed when Program participants make changes in the area or location of fallowed lands.

In addition to field verification by Metropolitan, Reclamation staff plan to conduct an independent verification during the spring and fall of 2019. Similar to past years' practice, Reclamation staff plans to select 5 percent of the acreage fallowed for inspection. On-site inspection would be made of all selected fields to observe fallowing conditions and take photographs. A report would be prepared that confirms extraordinary conservation implementation, and includes field observations and relevant photographs of fallowing conditions in PVID.

A calendar year 2019 Fallowed Land Verification Report will be prepared jointly by PVID, Metropolitan, and Reclamation in 2019. The Report will document the amount of water conserved in 2019 by the Program.

Limitations on the ICS Creation Amount: The amount of EC ICS created by Metropolitan in 2019 will be consistent with the limitations specified in the 2007 "Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations for Lake Powell and Lake Mead" (Interim Guidelines), the 2007 "California Agreement for the Creation and Delivery of Extraordinary Conservation Intentionally Created Surplus" (California Agreement), and the 2019 "Lower Basin Drought Contingency Operations" (LBOps), Exhibit 1 to the "Lower Basin Drought Contingency Plan Agreement," which is itself Attachment B to the 2019 "Agreement Concerning Colorado River Drought Contingency Management and Operations" (collectively, the Drought Contingency Plan or DCP).

Section XI.G.3.B.4 of the Interim Guidelines specifies that California contractors may create up to 400,000 acre-feet of EC ICS in Lake Mead in any given year. Paragraph 1 of the California Agreement specifies that Metropolitan may create up to 400,000 acre-feet of EC-ICS in Lake Mead in any given year, less the amount of EC ICS created by Imperial Irrigation District (IID) in that year. Therefore, Metropolitan's limitation to create EC ICS will be dependent upon the amount of EC ICS IID creates in 2019.

Metropolitan may request consultation for the use of annual ICS space unused by Arizona or Nevada as permitted by LBOps Section IV.B., if Metropolitan creates more EC ICS than is

-3- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 1

available to store in California's ICS storage capacity, and either Nevada and/or Arizona has unused annual space available. LBOps Section IV. B. provides that "[i]f one but not all of the Lower Division States reaches its annual Extraordinary Conservation ICS creation limit as set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines, and if there remains a desire to create additional amounts of Extraordinary Conservation ICS, the Secretary, provided there is no objection by any Lower Division State not reaching its annual limit, may authorize additional Extraordinary Conservation ICS creation within the total annual limitation set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines (625,000 acre-feet)."

Certification: Section XI.G.3.D.1 of the Interim Guidelines states the following:

A Contractor shall submit for the Secretary's review and verification, appropriate information, as determined by the Secretary, contained in a Certification Report, to demonstrate the amount of ICS created and that the method of creation was consistent with the Contractor's approved ICS plan, a Forbearance Agreement, and a Delivery Agreement. Such information shall be submitted in the Year following the creation of the ICS.

Metropolitan acknowledges this requirement and plans to submit a Certification Report demonstrating the amount of EC ICS created in 2019 that meets all specified requirements. Furthermore, Metropolitan acknowledges that, in accordance with Section 2.5.B of the Forbearance Agreement, USBR shall verify information in the Certification Report in consultation with the Lower Division States, and provide a final written decision to the parties concerning EC ICS creation.

Delivery: Metropolitan does not anticipate delivery of any EC ICS in 2019. Delivery of EC ICS created by Metropolitan is limited by the requirements of LBOps, the Interim Guidelines, and the California Agreement. LBOps (Section IV.D) establishes the following limitations on delivery of EC ICS:

( a) If the projected January 1 Lake Mead elevation is above 1,045 feet and at or below 1,075 feet, then the combined total delivery of EC ICS, Binational ICS, System Efficiency ICS and DCP ICS from Lake Mead to California Contractors shall be limited to 400,000 acre feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4 ), under such conditions Metropolitan is entitled to delivery of 350,000 acre-feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre feet. (b) If the projected January 1 Lake Mead elevation is above 1,025 feet and at or below 1,045 feet, then the combined total delivery of Extraordinary Conservation ICS, Binational ICS, System Efficiency ICS, DCP ICS, and the conversion of ICS to DCP ICS in Lake Mead for California Contractors shall be limited to 400,000 acre-feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4 ), under such conditions Metropolitan is entitled to delivery of 350,000 acre-

-4- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 1

feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre-feet. (c) If the projected January 1 Lake Mead elevation is at or below 1,025 feet, then no deli very of EC ICS is permitted.

-5- Final Plan for the Creation of EC JCS, Calendar Year 2019 Exhibit 2

Exhibit 2 The Metropolitan Water District of Southern California Imperial Irrigation District (IID) Water Conservation Program

JCS Category: Extraordinary conservation (EC) JCS Subcategories: Canal lining; reservoir construction; installation of non-leak gates; distribution system efficiency; irrigation system improvement

Term: December 22, 1988 - December 31, 2041, or 270 days beyond the termination of the October 10, 2003, Quantification Settlement Agreement, whichever is later, with extensions to this term as specified in the agreements. Metropolitan established the Agreement for the Implementation of a Water Conservation Program and Use of Conserved Water (Conservation Agreement) December 22, 1988, and the Approval Agreement (Approval Agreement) December 19, 1989. Both agreements have been amended.

Project Description: Under the Conservation Agreement (as amended) and the Approval Agreement (as amended), Metropolitan has funded water efficiency improvements within the Imperial Irrigation District's (IID) service area in return for IID's agreement to not use 105,000 AF of water annually.

The Program implemented structural and non-structural measures-extraordinary measures to conserve water-including, • concrete lining of 13 miles of existing main canals and 200 miles of lateral canals, • construction of two local reservoirs and three spill-interceptor canals with four reservoirs, • installation of 14 non-leak gates, • automation of the distribution system, • delivery of water to farmers on a 12-hour basis, • improvements in on-farm water management through the installation of drip irrigation systems, and • installation of tail water pumpback systems.

Through October 2018, Metropolitan has paid IID a total of $330.3 million for Program costs. Specific projects implemented as part of the Program are listed in the table below.

Project Name

Trifolium Reservoir Project

South Alamo Canal Lining Phase I Project

South Alamo Canal Lining Phase II Project

-6- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 2

Project Name "Z" Reservoir

Lateral Concrete Lining Project, 265 Miles

Rositas Supply Canal Concrete Lining Project

Vail Supply Canal Lining Project

Lateral Interceptor Pilot Project

Westside Main Canal Concrete Lining Project

System Automation Project

Non-Leak Gates Project

12-Hour Delivery Project

Irrigation Water Management Project

Modified East Lowline and Trifolium Interceptors, and Completion Projects

Annual ICS Creation Amount: The potential volume of projected water conservation during calendar year 2019 is 110,000 AF based on column 4 of Exhibit B to the October 10, 2003, Colorado River Water Delivery Agreement. Pursuant to the 1989 Approval Agreement, Metropolitan would reduce its use of water by up to 20,000 AF to allow Coachella Valley Water District (CVWD) to use this water should CVWD need this water. Exhibit H to the Lower Colorado River Basin JCS Forbearance Agreement provides that:

"The amount of EC ICS that can be created during any Year is limited to the amount of water resulting from the program that Metropolitan does not consumptively use, up to 105,000 AF, plus any reduction in calculated 11D conveyance losses as a result of 11D conveying less water through its conveyance and distribution system due to the conservation of water from this program. The volume of water conserved annually pursuant to this program to be devoted to the creation of EC ICS credits is further limited to the quantities set forth in the following ... :

Limitations on Creation of EC JCS

c) The amount of EC ICS created pursuant to this Exhibit is limited to the 11D reduction shown in column 4 of Exhibit B to the October 10, 2003, Colorado River

-7- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 2

Water Delivery Agreement, less any portion of that reduction that results in delivery of water to Coachella Valley Water District."

The HD reduction shown in column 4 of Exhibit B of the Colorado River Water Delivery Agreement is 110,000 AF for 2019. Absent this proposed creation of EC ICS, an amount of water equal to the proposed EC ICS would have been imported from the Colorado River.

Quantification Methodology: Between 1996 and 2006, Metropolitan and HD retained Conservation Verification Consultants (CVC) to develop a Systemwide Monitoring Program (SMP) to quantify and verify the EC created through the HD Water Conservation Program. Data collected under the SMP allows the identification and explanation of trends in HD system performance as a function of the operational environment within which the HD/Metropolitan conservation projects operated. The SMP was designed to function over the life of the IID/Metropolitan Program. The aims of the SMP are as follows: • Identify changes in on-farm irrigation practices. • Identify changes in main and lateral canal operations and zanjero accounting procedures. • Provide baseline data that can be used to separate water savings associated with HD/Metropolitan-sponsored conservation projects from water savings associated with measures implemented by others. • Provide data support for the five-year verification updates. • Fulfill the requirement for overall verification specified in the 1989 Approval Agreement.

Forty sites were selected and developed for the SMP. An automated data collection, quality control, processing, and retrieval system was developed under the HD/Metropolitan Program to collect and process flow data needed to quantify and verify the water conservation activities associated with the program. The system was designed to include many of the control sites for the various Program projects as well as the sites needed for systemwide monitoring. In December 1995, data processing procedures developed by the CVC were institutionalized and incorporated into HD's Water Information System.

Beginning January 1, 1996, conservation verification data were processed and stored using Water Information System applications and capabilities. HD data collected prior to January 1, 1996, which were processed by the CVC for use in determining annual projected water conservation savings over the life of the Program, were also stored in the Water Information System. The Water Information System management system was developed to generate daily, monthly, calendar year, and water year tables, summary tables and bar charts presented in annual Processed Flow Data documents and annual Projected Water Conservation Savings reports that quantify and verify water conserved as a result of the Program. Published Projected Water Conservation Savings reports have been provided to USBR.

Verification Methodology: As noted above, the methods for verifying water conserved as a result of the IID Water Conservation Program are the same as the methods used to quantify that

-8- Final Plan for the Creation of EC JCS, Calendar Year 2019 Exhibit 2

water conservation. Through 2006, the CVC prepared and presented to the Water Conservation Measurement Committee an annual report on the estimated amount of water conserved by the Program and each project thereof. These annual reports served as verification of the water conserved under the Pro gram.

Limitations on the ICS Creation Amount: The amount of EC JCS created by Metropolitan in 2019 will be consistent with the limitations specified in the 2007 "Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations for Lake Powell and Lake Mead" (Interim Guidelines), the 2007 "California Agreement for the Creation and Delivery of Extraordinary Conservation Intentionally Created Surplus" (California Agreement), and the 2019 "Lower Basin Drought Contingency Operations" (LBOps), Exhibit 1 to the "Lower Basin Drought Contingency Plan Agreement," which is itself Attachment B to the 2019 "Agreement Concerning Colorado River Drought Contingency Management and Operations" (collectively, the Drought Contingency Plan or DCP).

Section XI.G.3.B.4 of the Interim Guidelines specifies that California contractors may create up to 400,000 acre-feet of EC JCS in Lake Mead in any given year. Paragraph 1 of the California Agreement specifies that Metropolitan may create up to 400,000 acre-feet of EC-JCS in Lake Mead in any given year, less the amount of EC JCS created by Imperial Irrigation District (IID) in that year. Therefore, Metropolitan's limitation to create EC JCS will be dependent upon the amount of EC JCS HD creates in 2019.

Metropolitan may request consultation for the use of annual JCS space unused by Arizona or Nevada as permitted by LBOps Section IV.B., if Metropolitan creates more EC JCS than is available to store in California's JCS storage capacity, and either Nevada and/or Arizona has unused annual space available. LBOps Section IV. B. provides that "[i]f one but not all of the Lower Division States reaches its annual Extraordinary Conservation JCS creation limit as set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines, and if there remains a desire to create additional amounts of Extraordinary Conservation JCS, the Secretary, provided there is no objection by any Lower Division State not reaching its annual limit, may authorize additional Extraordinary Conservation JCS creation within the total annual limitation set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines (625,000 acre-feet)."

Certification: Section XI.G.3.D. l of the Interim Guidelines states the following:

A Contractor shall submit for the Secretary's review and verification, appropriate information, as determined by the Secretary, contained in a Certification Report, to demonstrate the amount of JCS created and that the method of creation was consistent with the Contractor's approved JCS plan, a Forbearance Agreement, and a Delivery Agreement. Such information shall be submitted in the Year following the creation of the JCS.

Metropolitan acknowledges this requirement and plans to submit a Certification Report demonstrating the amount of EC JCS created in 2019 that meets all specified requirements.

-9- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 2

Furthermore, Metropolitan acknowledges that, in accordance with Section 2.5.B of the Forbearance Agreement, USBR shall verify information in the Certification Report in consultation with the Lower Division States, and provide a final written decision to the parties concerning EC ICS creation.

(a) If the projected January 1 Lake Mead elevation is above 1,045 feet and at or below 1,075 feet, then the combined total delivery of EC ICS, Binational ICS, System Efficiency ICS and DCP ICS from Lake Mead to California Contractors shall be limited to 400,000 acre feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4 ), under such conditions Metropolitan is entitled to delivery of 350,000 acre-feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre feet. (b) If the projected January 1 Lake Mead elevation is above 1,025 feet and at or below 1,045 feet, then the combined total delivery of Extraordinary Conservation ICS, Binational ICS, System Efficiency ICS, DCP ICS, and the conversion of ICS to DCP ICS in Lake Mead for California Contractors shall be limited to 400,000 acre-feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4), under such conditions Metropolitan is entitled to delivery of 350,000 acre feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre-feet. (c) If the projected January 1 Lake Mead elevation is at or below 1,025 feet, then no delivery of EC ICS is permitted.

-10- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 3

Exhibit 3 The Metropolitan Water District of Southern California Water Supply from Desalination

ICS Category: Extraordinary conservation (EC) ICS Subcategory: Groundwater desalination

Term: The terms of Metropolitan' s agreements to fund groundwater desalination projects in its service are are variable, as described in the Project Description section. However, since groundwater desalination facilities are permanent capital improvement projects, they result in ongoing water conservation over the life of the project, regardless of whether Metropolitan' s funding term has ended. Therefore, there is no fixed end date for the EC ICS creation associated with these projects. The projects presented in this Exhibit are expected to yield EC ICS for Metropolitan in 2019 and indefinitely into the future. Funding terms are listed in the table below

Term of Metropolitan Project Financial Suooort Arlington Basin Groundwater Desalter Project 1990-2010 Beverly Hills Desalter 2003-2023 Cal Poly Pomona Water Treatment Plant 2016-2041 Capistrano Beach Desalter 2007-2027 Chino Basin Desalination Program 2000-2031 Irvine Desalter 2007-2027 IRWD Wells 21 and 22 Desalter 2012-2037 Lower Sweetwater River Basin Groundwater Demineralization Project, Phase I 2000-2015 Madrona Desalination Facility 2002-2022 Menifee Desalter 2002-2022 Mesa Colored Water Treatment Facility 2001-2025 Oceanside Desalter (Mission Basin Expansion) 1993-2023 Round Mountain Water Treatment Plant 2015-2040 San Juan Basin Desalter 2004-2024 Tapo Canyon Water Treatment Plant 2005-2014 Temescal Basin Desalter 2001-2025 Tustin Desalter 1996-2016 West Basin C. Marvin Brewer Desalter No. I 1993-2013

Project Description: Metropolitan supports several of its member agencies financially to implement groundwater desalination projects in its service area. Metropolitan enters into an agreement to pay for water produced by an individual project for a multi-year term. Metropolitan offers three Local Resources Program incentive payment structure options to choose from: sliding scale incentives up to $340 per acre-foot over 25 years, sliding scale incentives up to $475 per AF over 15 years, or fixed incentives up to $305 per AF over 15 years.

-11- Final Plan for the Creation of EC JCS, Calendar Year 2019 Exhibit 3

In order to determine the appropriate Metropolitan contribution, agencies are required to submit to Metropolitan annual project costs and production data at the conclusion of each fiscal year of operation.

Descriptions of the individual groundwater desalination projects in Metropolitan's service area funded by Metropolitan and/or other water agencies for calendar year 2019 are provided in the sub-sections below.

Arlington Basin Groundwater Desalter Project

The Arlington Basin Groundwater Desalter Project includes extraction wells, pumps and piping, reverse osmosis, granular activated carbon filters, and brine disposal facilities. The project extracts and desalts non-potable groundwater from the Arlington Basin. Product water is then distributed for general municipal, domestic, and industrial purposes. Concentrate is disposed to the ocean through the Santa Ana Regional Interceptor line. In fiscal year 2003/04, the project commenced production of potable water, which is purchased by the City of Norco.

Beverly Hills Desalter

The Beverly Hills Desalter includes a treatment plant, extraction wells, a collection pipeline, a booster pump, a product water pipeline to connect to Beverly Hills' water distribution system, and a concentrate waste disposal pipeline. The project pumps and treats brackish groundwater from the Hollywood Basin. Concentrate is discharged to the sanitary sewer system through which it is conveyed to the City of Los Angeles' Hyperion Wastewater Treatment Plant. The 20- year funding agreement between Metropolitan and the City of Beverly Hills terminates at the end of April 2023.

Cal Poly Pomona Water Treatment Plant

The Cal Poly Pomona Water Treatment Plant consists of new groundwater feed, bypass flow control system, reverse osmosis treatment plant, chemical storage and feed system, disinfection, a pump station, a product water pipeline, and a concentrate disposal pipeline. Brackish water is pumped from the Spadra Groundwater Basin. Product water is delivered to the California State Polytechnic University, Pomona (Cal Poly Pomona) campus for domestic use. Concentrate is conveyed to the ocean through the Los Angeles County Sanitation District industrial waste line. The project commenced operation in April 2017. The 25-year funding agreement between Metropolitan, Three Valleys Municipal Water District, and Cal Poly Pomona terminates at the end of July 2041.

Capistrano Beach Desalter

The Capistrano Beach Desalter includes a treatment plant, extraction wells, a collection pipeline, a booster pump, a product water pipeline to connect to South Coast Water District's water distribution system, and a concentrate waste disposal pipeline. The project pumps and treats

-12- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 3

brackish groundwater from the San Juan Basin. Concentrate is discharged to the Chiquita Ocean Outfall. The 20-year funding agreement between Metropolitan, Municipal Water District of Orange County and the South Coast Water District will terminate on June 30, 2026.

Chino Basin Desalination Program

The Chino Basin Desalination Program includes two separate groundwater desalters and distribution systems. The Chino Basin Desalter No. 1 treats groundwater containing high concentrations of total dissolved solids, nitrates, and volatile organic compounds, and conveys product water to the cities of Chino, Chino Hills, and Norco and Jurupa Community Services District. Groundwater is pumped from 14 wells throughout the Chino Basin area to the Desalter, where reverse osmosis, ion exchange and air stripping processes are utilized. The project includes a pipeline and structures connecting existing Jurupa and City of Ontario water systems, a three-million gallon reservoir, and two booster pumping stations. Brine is transported by a regional brine line and subsequently discharged to the ocean. The Chino Basin Desalter No. 1 design capacity is 14.2 million gallons per day.

The Chino Basin Desalter No. 2 serves water to Jurupa, Ontario, Norco and the Santa Ana River Water Company. Groundwater pumped from fourteen wells is treated at this plant using reverse osmosis and ion exchange processes. The project also includes raw water pipelines to convey groundwater to the desalting facilities, pipelines to convey treated water to the existing potable systems, a three-million gallon clearwell, a five-million gallon storage reservoir, five booster pumping stations, and one brine concentrate reduction facility. The Chino Basin Desalter No. 2 design capacity is 17.2 million gallons per day.

In 2011, Metropolitan entered into a consolidated agreement under the Local Resources Program with the Inland Empire Utilities Agency, Western Municipal Water District, and Chino Basin Desalter Authority to fund the Chino Basin Desalination Program over a 20-year term, terminating in June 2031.

Irvine Desalter

The Irvine Desalter includes a seven million gallon per day reverse osmosis desalination system, nine wells, yard piping, and brine disposal piping. Treatment facilities consist of threshold inhibitor and acid injection systems, cartridge filters, booster pumps, reverse osmosis membrane units, decarbonation facilities, chlorine disinfection, and an on-site storage reservoir. Brackish water is pumped from the Orange County Basin. Product water is delivered to the Irvine Ranch Water District's (IRWD) service area. Brine is discharged at the County Sanitation Districts of Orange County (CSDOC) facility in Fountain Valley. The 20-year funding agreement between Metropolitan, Municipal Water District of Orange County, Orange County Water District (OCWD) and IRWD will terminate at the end of August 2027.

-13- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 3

IRWD Deep Aquifer Treatment System Project

IRWD's Deep Aquifer Treatment System (OATS) purifies drinking water from the lower aquifer of the Orange County Groundwater Basin, which has a brownish tint. The OATS facility began operation in 2002. The project includes two wells and a nano-filtration treatment plant. Product water is delivered to IRWD's service area and brine is discharged at the County Sanitation District of Orange County facility in Fountain Valley. This project has been funded by Metropolitan's customers in Metropolitan's service area.

IRWD Wells 21 and 22 Desalter

The IRWD's Wells 21 and 22 Desalter includes rehabilitation of a treatment plant, brine disposal and pipelines. The treatment plant employs reverse osmosis and cartridge filters to remove total dissolved solids and nitrates. Product water is delivered to IRWD's existing 42-inch diameter pipeline. The brine concentrate is conveyed to the Orange County Sanitation District's existing sewer system. The 25-year funding agreement between Metropolitan and IRWD terminates at the end of June 203 7.

Lower Sweetwater River Basin Groundwater Demineralization Project, Phases I and II

The Lower Sweetwater River Basin Groundwater Demineralization Project, Phases I and II includes wells, replenishment facilities, a treatment plant, neutralization plant, brine disposal, and pipelines. The treatment plant employs reverse osmosis and blending to desalt brackish water. Product water is pumped to the Sweetwater Authority's distribution system for use by National City and South Bay Irrigation District. Concentrate is discharged to San Diego Bay through the Upper Paradise Creek flood control channel. The 20-year funding agreement between Metropolitan and the San Diego County Water Authority terminated in October 2015.

Madrona Desalination Facility

The Madrona Desalination Facility includes two wells and treatment of water from the West Coast Basin by reverse osmosis. Product water is conveyed to the City of Torrance's distribution system by booster pump. Concentrate is discharged to the ocean. The 20-year funding agreement between Metropolitan and the City of Torrance terminates at the end of June 2022.

Menifee Desalter

The Menifee Desalter treats brackish water from five wells in the Perris and Menifee Subbasins through reverse osmosis. Product water is pumped into Eastern Municipal Water District's potable distribution system. Concentrate is disposed through the Temescal Valley and Santa Ana regional interceptors to the ocean. The 20-year funding agreement between Metropolitan and Eastern Municipal Water District terminates at the end of November 2021.

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Mesa Colored Water Treatment Facility

Located in Costa Mesa, the Mesa Colored Water Treatment Facility pumps and treats ancient colored groundwater from the Orange County groundwater basin to augment Mesa Water District's (Mesa) domestic water supply. The project commenced operation in 2000 and includes nano-filtration, wells, a storage tank, and a pump station._The current 25-year funding agreement between Metropolitan, Municipal Water District of Orange County, and Mesa terminates at the end of June 2025.

Oceanside Desalter (Mission Basin Expansion)

The Oceanside Desalter (Mission Basin Expansion) includes three wells, a cartridge filtration facility, and water conveyance facilities. Brackish water is pumped from the Mission Basin. Product water is delivered to the City of Oceanside. Concentrate is disposed into the ocean. The current 20-year funding agreement between Metropolitan and the San Diego County Water Authority terminates at the end of July 2023.

Perris I Desalter

The Perris I Desalter includes nine wells and a reverse osmosis treatment plant. It began operation in 2005 and treats degraded groundwater from the Perris South Groundwater Basin. Product water is delivered to Eastern Municipal Water District's service area and brine is discharged at the County Sanitation District of Orange County facility in Fountain Valley via the Inland Empire Brine Line. This project has been funded by Metropolitan' s customers in Metropolitan' s service area.

Round Mountain Water Treatment Plant

The Round Mountain Water Treatment Plant consists of installing a new vertical turbine pump and controls within an existing well site, a one-million-gallon-per-day reverse osmosis treatment facility, well supply pipeline, finished water pipeline, and a concentrate disposal pipeline. The treatment plant will include pre-filtration to remove iron and manganese, followed by reverse osmosis treatment to meet regulatory drinking water standards. The finished water will be pumped into Camrosa Water District's existing distribution system. Concentrate is conveyed to the ocean through the Calleguas Municipal Water District's Salinity Management Pipeline. The 25-year funding agreement between Metropolitan, Calleguas Municipal Water District, and Camrosa Water District terminates at the end of July 2040.

San Juan Basin Desalter

The San Juan Basin Desalter consists of five wells, a four-million-gallon-per-day reverse osmosis treatment plant, pretreatment to remove iron and manganese, a pump station, a product water pipeline, and a concentrate disposal pipeline. Brackish water is pumped from the Lower San Juan Basin. Product water is delivered to the Capistrano Valley Water District. Concentrate

-15- Final Plan for the Creation of EC JCS, Calendar Year 2019 Exhibit 3

is conveyed to the ocean through the Chiquita Land Outfall and the Serra Ocean Outfall. The 20- year funding agreement between Metropolitan and the Municipal Water District of Orange County terminates at the end of December 2024.

Tapo Canyon Water Treatment Plant

The Tapo Canyon Water Treatment Plant includes wells, a two million gallon per day reverse osmosis desalination plant, storage tanks, and pipeline. Brackish water is pumped from the Simi Valley Groundwater Basin. Product water is delivered to the City of Simi Valley. Brine is conveyed to the existing sewer system. The 25-year funding agreement between Metropolitan and the Calleguas Municipal Water District was terminated in October 2014.

Temescal Basin Desalter

The Temescal Basin Desalter includes wells, reverse osmosis treatment, and transmission, product water, and brine disposal pipelines. Brackish water is pumped from the Temescal Subbasin. Product water is delivered to the City of Corona. Brine is discharged to the ocean through the Santa Ana Regional Interceptor. The 25-year funding agreement between Metropolitan and Western Municipal Water District terminates at the end of June 2025.

Tustin Desalter

The Tustin Desalter includes wells, a two million gallon per day reverse osmosis desalination plant, and pipeline. Brackish water is pumped from the Orange County Basin. Product water is delivered to the City of Tustin. Brine is conveyed to the County Sanitation Districts of Orange County wastewater treatment facilities via a sewer. The 20-year funding agreement between Metropolitan and the Municipal Water District of Orange County terminated at the end of August 2016.

West Basin C. Marvin Brewer Desalter No. 1

The West Basin C. Marvin Brewer Desalter No. 1 includes a 1.5-million-gallon-per-day reverse osmosis desalination system, yard piping, and brine disposal piping. Treatment facilities consist of threshold inhibitor and acid injection systems, cartridge filters, booster pumps, reverse osmosis membrane units, decarbonation facilities, chlorine disinfection, and an on-site storage reservoir. Brackish water is pumped from the West Coast Basin. Product water is delivered to the California Water Service Company. Brine is disposed and conveyed to the Los Angeles County Sanitation District's Carson Industrial Wastewater Treatment Plant. The twenty-year funding agreement between Metropolitan and West Basin Municipal Water District terminated at the end of May 2013.

Annual ICS Creation Amount: Metropolitan expects the groundwater desalination projects that it funds or has funded within its service area to allow for the creation of EC JCS up to the total desalination capacity of each project. The capacities of these projects, and therefore the planned

-16- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 3

EC ICS creation in 2019, are listed in the table below. Absent this proposed creation of EC ICS, an amount of water equal to the proposed EC ICS would have been imported from the Colorado River.

Project Capacity Project (acre-feet per year) Arlington Basin Groundwater Desalter Project 6,100 Beverly Hills Desalter 2,600 Cal Poly Pomona Water Treatment Plant 250 Capistrano Beach Desalter 1,300 Chino Basin Desalination Program 35,200 Irvine Desalter 6,700 IRWD Deep Aquifer Treatment System Project 8,300 IRWD Wells 21 and 22 Desalter 6,400 Lower Sweetwater River Basin Groundwater 8,800 Demineralization Project, Phases I and II Madrona Desalination Facility 2,400 Menifee Desalter 3,360 Mesa Colored Water Treatment Facility 11,300 Oceanside Desalter (Mission Basin Expansion) 6,500 Perris I Desalter 6,000 Round Mountain Water Treatment Plant 1,000 San Juan Basin Desalter 5,760 Tapo Canyon Water Treatment Plant 1,180 Temescal Basin Desalter 12,000 Tustin Desalter 3,200 West Basin C. Marvin Brewer Desalter No. I 1,524 Total 129,874

Quantification Methodology: Project water produced by the groundwater desalination projects described in this Exhibit is metered at the desalination facility to measure the amount of project water that was pumped into the agency's distribution system. The agency that operates the desalination facility then reports the metered quantities of desalinated water to Metropolitan via online systems, email, or regular mail.

Verification Methodology: Metropolitan verifies the amount of desalted water production and associated project unit cost through an annual reconciliation process. In addition, Metropolitan periodically conducts an audit of agencies' records pertaining to desalted water production and costs. Upon request, Metropolitan will make available to Reclamation for inspection Metropolitan's verification file for any of the groundwater desalination projects described in Exhibit 3, including water conservation measurement data provided by member agencies.

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Section XI.G.3.B.4 of the Interim Guidelines specifies that California contractors may create up to 400,000 acre-feet of EC ICS in Lake Mead in any given year. Paragraph 1 of the California Agreement specifies that Metropolitan may create up to 400,000 acre-feet of EC-ICS in Lake Mead in any given year, less the amount of EC ICS created by Imperial Irrigation District (IID) in that year. Therefore, Metropolitan' s limitation to create EC ICS will be dependent upon the amount of EC ICS IID creates in 2019.

Metropolitan may request consultation for the use of annual ICS space unused by Arizona or Nevada as permitted by LBOps Section IV.B., if Metropolitan creates more EC ICS than is available to store in California's ICS storage capacity, and either Nevada and/or Arizona has unused annual space available. LBOps Section IV. B. provides that "[i]f one but not all of the Lower Division States reaches its annual Extraordinary Conservation ICS creation limit as set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines, and if there remains a desire to create additional amounts of Extraordinary Conservation ICS, the Secretary, provided there is no objection by any Lower Division State not reaching its annual limit, may authorize additional Extraordinary Conservation ICS creation within the total annual limitation set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines (625,000 acre-feet)."

Certification: Section XI.G.3.D.1 of the Interim Guidelines states the following:

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(a) If the projected January 1 Lake Mead elevation is above 1,045 feet and at or below 1,075 feet, then the combined total delivery of EC ICS, Binational ICS, System Efficiency ICS and DCP ICS from Lake Mead to California Contractors shall be limited to 400,000 acre feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4 ), under such conditions Metropolitan is entitled to delivery of 350,000 acre-feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre feet. (b) If the projected January 1 Lake Mead elevation is above 1,025 feet and at or below 1,045 feet, then the combined total delivery of Extraordinary Conservation ICS, Binational ICS, System Efficiency ICS, DCP ICS, and the conversion of ICS to DCP ICS in Lake Mead for California Contractors shall be limited to 400,000 acre-feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4), under such conditions Metropolitan is entitled to delivery of 350,000 acre feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre-feet. (c) If the projected January 1 Lake Mead elevation is at or below 1,025 feet, then no delivery of EC ICS is permitted.

-19- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 4

Exhibit 4 The Metropolitan Water District of Southern California Lower Colorado Water Supply Project

ICS Category: Extraordinary conservation (EC) ICS Subcategory: Development and acquisition of a non-Colorado River System groundwater supply used in lieu of mainstream water within the same state

Term: 1996-December 31, 2045. Metropolitan's Project contract with the United States (represented by USBR) and the City of Needles terminates on December 31, 2045. If Needles elects to exercise its option under a separate contract with USBR to renew that contract for an additional term of 50 years ending on December 31, 2095, Metropolitan has the option to renew its Project contract for an additional term of 50 years. Unused Project capacity is projected to be available to Metropolitan through 2059.

Project Description: In 1986, Public Law 99-655, the Lower Colorado Water Supply Act, authorized the Secretary, through Reclamation, to construct, operate, and maintain the Lower Colorado Water Supply Project (Project). The Project is comprised of a well field that pumps groundwater from the Sand Hills area of California into the All-American Canal. The purpose of the Project at the time of its authorization was to provide an alternative water supply for parties using Colorado River water without rights or with insufficient rights. These parties pay the Project costs for producing water and exchanging that water with IID. The Project is authorized to supply up to 10,000 AF of water annually. Under a contract with Reclamation, the City of Needles assumed the administrative responsibility for non-federal Project beneficiaries within San Bernardino, Riverside, and Imperial Counties. Stage 1 of the Project was completed in 1996.

In 2005, Public Law 109-103 amended the Act to authorize the Secretary to contract with certain additional entities for the use of Project water under such terms as the Secretary determined would benefit the interest of Project users along the Colorado River. Through 2006, contracting parties used about 1,000 AF of water from the Project annually with the primary user of the Project being Needles. There was a concern that, over time, the groundwater pumped by the Project would become too saline for use leaving the Project beneficiaries without an available water supply. On March 26, 2007, Reclamation, Needles, and Metropolitan entered into a contract allowing Metropolitan to access the unused capacity of the Project. The contract ensures no interference with the USBR's management of Colorado River system reservoirs and regulatory structures.

Annual ICS Creation Amount: The Project is projected to conserve 10,000 AF of water during calendar year 2019, based on the operation of four wells. The portion of that conservation credited to Metropolitan is the Project's unused capacity. If unused Project capacity in 2019 is based on the amount of water used by other contractors and Needles' subcontractors in 2017, then approximately 9,500 acre-feet would be available to Metropolitan as EC ICS in 2019. Absent this proposed creation of EC ICS, an amount of water equal to the proposed EC ICS would have been imported from the Colorado River.

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Quantification Methodology: Project water will be measured at point(s) designated by USBR. The measuring and controlling devices remain at all times under the control of USBR. Authorized representatives of Reclamation have access to the measuring and controlling devices at all times. Reclamation reports the amount of Project water discharged into the All-American Canal on a monthly basis. Reclamation's "Colorado River Accounting and Water Use Report, Arizona, California, and Nevada, Calendar Year 2019" will document the actual amount of Project water that was made available to Metropolitan in 2019.

Verification Methodology: The methods used to verify the amount of EC ICS credited to Metropolitan as a result of the Project are not distinct from Metropolitan's method of quantifying the EC ICS. Thus, the verification methodology is implicitly explained in the Quantification Methodology section.

Section XI.G.3.B.4 of the Interim Guidelines specifies that California contractors may create up to 400,000 acre-feet of EC ICS in Lake Mead in any given year. Paragraph 1 of the California Agreement specifies that Metropolitan may create up to 400,000 acre-feet of EC-ICS in Lake Mead in any given year, less the amount of EC ICS created by Imperial Irrigation District (IID) in that year. Therefore, Metropolitan' s limitation to create EC ICS will be dependent upon the amount of EC ICS IID creates in 2019.

Certification: Section XI.G.3.D.1 of the Interim Guidelines states the following:

-21- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 4

(a) If the projected January 1 Lake Mead elevation is above 1,045 feet and at or below 1,075 feet, then the combined total delivery of EC ICS, Binational ICS, System Efficiency ICS and DCP ICS from Lake Mead to California Contractors shall be limited to 400,000 acre feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4 ), under such conditions Metropolitan is entitled to delivery of 350,000 acre-feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre feet. (b) If the projected January 1 Lake Mead elevation is above 1,025 feet and at or below 1,045 feet, then the combined total delivery of Extraordinary Conservation ICS, Binational ICS, System Efficiency ICS, DCP ICS, and the conversion of ICS to DCP ICS in Lake Mead for California Contractors shall be limited to 400,000 acre-feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4), under such conditions Metropolitan is entitled to delivery of 350,000 acre feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre-feet. (c) If the projected January 1 Lake Mead elevation is at or below 1,025 feet, then no delivery of EC ICS is permitted.

-22- Final Plan for the Creation of EC JCS, Calendar Year 2019 Exhibit 5

Exhibit 5 The Metropolitan Water District of Southern California Landscape Transformation Program

ICS Category: Extraordinary conservation (EC) JCS Subcategory: Urban turf removal and landscaping

Term: 2014 - 2020

Project Description: The Landscape Transformation Program (Program) is an urban turf removal and landscaping program whereby Metropolitan funds incentives for homeowners to replace turf with drought-tolerant landscapes that require less water. About 148 million square feet of lawn turf has been removed as a result of the Program over the two-fiscal-year period of 2014-15 and 2015-16. This program saves 24,000 acre-feet per year. Metropolitan recently renewed its turf removal program in July 2018 to encourage additional outdoor conservation in Southern California. The program offers an incentive of $2 per square foot for turf removal and has an annual budget limit of $50 million, which will result in an estimated savings of 10,125 acre-feet per year. Following the success of other incentive programs focusing on landscaping and turf grass removal, the 2019-20 Program aims to combine turf removal, irrigation modification, and rainwater retention or filtration to support reuse or soil absorption of rainwater. Metropolitan' s member and retail agencies also implement local residential water conservation programs within their respective service areas and receive Metropolitan incentives. Projects include turf removal programs. To create Extraordinary Conservation Intentionally Created Surplus (EC JCS), Metropolitan would reduce its use of Colorado River water in an amount up to the amount of water conserved by the turf removal component of the Program in its service area. Absent the Program, such water would have have been beneficially used.

Annual ICS Creation Amount: The amount of EC JCS created as a result of the Program during any given year is the amount of water conserved by turf removal in Metropolitan's service area. Metropolitan expects to conserve 34,125 acre-feet (AF) of water via turf removal in calendar year 2019 and to create up to the same amount of EC JCS as a result of the Program. Absent this proposed creation of EC JCS, an amount of water equal to the proposed EC JCS would have been imported from the Colorado River.

Quantification Methodology: As a wholesale water district, Metropolitan does not have retail customers or access to retail delivery systems by which to monitor actual water use and determine directly the amount of water saved via the Program. Instead, Metropolitan determines water savings based on studies of similar programs and an estimated landscape duration of 30 years for lifetime water savings. Based on previous studies, turf replacement programs conserve 44 gallons/square foot/year (0.000135 AF/square foot/year). Therefore, net annual water savings (after establishment of low water use plants) due to the Program are calculated according to the following equation:

Annual water savings = Area of turf replaced (square feet) x (0.000135 AF/feet2/year)

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Verification Methodology: Metropolitan verifies that turf has been removed from each project using photographs submitted by the Program applicant. Each applicant must submit a minimum of five pre-project photographs before they can obtain approval to proceed with their project. Once the project is completed, the applicant must submit at least another five photographs of their finished project in order to receive payment. Metropolitan also randomly conducts aerial and physical inspections to ensure that project area measurements are correct. As part of its ICS Certification Report, Metropolitan will provide records demonstrating the area of turf removed (in square feet) during 2019 and the corresponding amount of water conserved.

Limitations on the ICS Creation Amount: The amount of EC ICS created by Metropolitan in 2019 will be consistent with the limitations specified in the 2007 "Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations for Lake Powell and Lake Mead" (Interim Guidelines), the 2007 "California Agreement for the Creation and Delivery of Extraordinary Conservation Intentionally Created Surplus" (California Agreement), and the 2019 "Lower Basin Drought Contingency Operations" (LB Ops), Exhibit 1 to the "Lower Basin Drought Contingency Plan Agreement," which is itself Attachment B to the 2019 "Agreement Concerning Colorado River Drought Contingency Management and Operations" (collectively, the Drought Contingency Plan or DCP).

Certification: Section XI.G.3.D.1 of the Interim Guidelines states the following:

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Agreement. Such information shall be submitted in the Year following the creation of the JCS.

Metropolitan acknowledges this requirement and plans to submit a Certification Report demonstrating the amount of EC JCS created in 2019 that meets all specified requirements. Furthermore, Metropolitan acknowledges that, in accordance with Section 2.5.B of the Forbearance Agreement, USBR shall verify information in the Certification Report in consultation with the Lower Division States, and provide a final written decision to the parties concerning EC JCS creation.

Delivery: Metropolitan does not anticipate delivery of any EC JCS in 2019. Delivery of EC JCS created by Metropolitan is limited by the requirements of LBOps, the Interim Guidelines, and the California Agreement. LBOps (Section IV.D) establishes the following limitations on delivery of EC JCS:

(a) If the projected January 1 Lake Mead elevation is above 1,045 feet and at or below 1,075 feet, then the combined total delivery of EC JCS, Binational JCS, System Efficiency JCS and DCP JCS from Lake Mead to California Contractors shall be limited to 400,000 acre feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4 ), under such conditions Metropolitan is entitled to delivery of 350,000 acre-feet of JCS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre feet. (b) If the projected January 1 Lake Mead elevation is above 1,025 feet and at or below 1,045 feet, then the combined total delivery of Extraordinary Conservation JCS, Binational JCS, System Efficiency JCS, DCP JCS, and the conversion of JCS to DCP JCS in Lake Mead for California Contractors shall be limited to 400,000 acre-feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4), under such conditions Metropolitan is entitled to delivery of 350,000 acre feet of JCS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre-feet. (c) If the projected January 1 Lake Mead elevation is at or below 1,025 feet, then no delivery of EC JCS is permitted.

-25- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 6

Exhibit 6 The Metropolitan Water District of Southern California Indoor Water Conservation Devices

ICS Category: Extraordinary conservation (EC) ICS Subcategory: Urban water conservation devices

Term: 1990 - 2026

Project Description: Metropolitan provides rebates to both residential and commercial consumers to encourage the use of water-efficient indoor and outdoor products. The conservation rebate program started in 1990, focusing mainly on indoor fixtures such as toilets, showerheads and faucet aerators. Current indoor rebates include high-efficiency clothes washers, premium high-efficiency toilets, zero/ultra-low water urinals, dry vacuum pumps, connectionless food steamers, air-cooled ice machines, laminar flow restrictors, and plumbing flow controls. Most rebates are processed through Metropolitan's regional rebate program, SoCal Water$mart, where customers can easily get program information, apply online for a rebate and check their rebate status. Some of Metropolitan's member agencies also have their own indoor conservation programs where they may either directly install water efficient fixtures or have large product distributions along with issuing rebates. The benefits of the devices last up to 20 years after installation.

Annual ICS Creation Amount: The table below summarizes the number of indoor water conservation devices installed from 1990 through 2018, the projected 2019 water savings, lifetime savings with lives between two and 20 years depending upon the device, and rebates associated with existing programs. 2019 EC ICS creation as a result of the program could be up to the projected 2019 water savings of 91,383 acre-feet. Absent this proposed creation of EC ICS, an amount of water equal to the proposed EC ICS would have been imported from the Colorado River.

Projected 2019 Lifetime Number Rebates to Date Category water savings Savings of Devices (million dollars) (acre-feet) (acre-feet)

Commercial 380,843 11,910 290,210 45.8

Residential 6,011,372 79,473 2,566,414 294.0

Total 6,392,215 91,383 2,856,624 339.8

Quantification Methodology: Estimates of water savings in any given year due to the indoor water conservation device program are based on an average annual savings factor from the

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manufacturers' specifications. This savings factor is multiplied by the quantity of devices installed to determine total water savings. Water savings are calculated on an annual basis and begin being credited for the entire calendar year in which Metropolitan pays the rebate. After the lifetime of the device is reached, its savings are removed from the spreadsheet which calculates savings. Attachment 1 is a list of existing indoor water conservation devices. As new devices become available and implemented, they will be described in the annual Plan of Creation.

Verification Methodology: There are multiple processes in place to ensure that each indoor rebate application submitted by an applicant can be verified. In order to receive a rebate check, an applicant must submit a copy of the product receipt with the rebate application. The application is then validated by verifying that the product meets program requirements and that the applicant's address is within Metropolitan's service area boundaries. Past program participation is also checked through Metropolitan' s database to ensure non-duplication. Additionally, Metropolitan randomly conducts physical inspections to ensure that projects meet program requirements. Metropolitan will, as part of its ICS Certification Report, provide records demonstrating the number and types of devices installed and the corresponding amount of water conserved from these devices in each calendar year.

Limitations on the ICS Creation Amount: The amount of EC ICS created by Metropolitan in 2019 will be consistent with the limitations specified in the 2007 "Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations for Lake Powell and Lake Mead" (Interim Guidelines), the 2007 "California Agreement for the Creation and Delivery of Extraordinary Conservation Intentionally Created Surplus" (California Agreement), and the 2019 "Lower Basin Drought Contingency Operations" (LB Ops), Exhibit 1 to the "Lower Basin Drought Contingency Plan Agreement," which is itself Attachment B to the 2019 "Agreement Concerning Colorado River Drought Contingency Management and Operations" (collectively, the Drought Contingency Plan or DCP).

Section XI.G.3.B.4 of the Interim Guidelines specifies that California contractors may create up to 400,000 acre-feet of EC ICS in Lake Mead in any given year. Paragraph 1 of the California Agreement specifies that Metropolitan may create up to 400,000 acre-feet of EC-ICS in Lake Mead in any given year, less the amount of EC ICS created by Imperial Irrigation District (11D) in that year. Therefore, Metropolitan' s limitation to create EC ICS will be dependent upon the amount of EC ICS IID creates in 2019.

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Extraordinary Conservation ICS creation within the total annual limitation set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines (625,000 acre-feet)."

Certification: Section XI.G.3.D. l of the Interim Guidelines states the following:

Delivery: Metropolitan does not anticipate delivery of any EC ICS in 2019. Delivery of EC ICS created by Metropolitan is limited by the requirements of LBOps, the Interim Guidelines, and the California Agreement. LB Ops (Section IV .D) establishes the following limitations on delivery of EC ICS:

(a) If the projected January I Lake Mead elevation is above 1,045 feet and at or below 1,075 feet, then the combined total delivery of EC ICS, Binational ICS, System Efficiency ICS and DCP ICS from Lake Mead to California Contractors shall be limited to 400,000 acre feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4), under such conditions Metropolitan is entitled to delivery of 350,000 acre-feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre feet. (b) If the projected January 1 Lake Mead elevation is above 1,025 feet and at or below 1,045 feet, then the combined total delivery of Extraordinary Conservation ICS, Binational ICS, System Efficiency ICS, DCP ICS, and the conversion of ICS to DCP ICS in Lake Mead for California Contractors shall be limited to 400,000 acre-feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4), under such conditions Metropolitan is entitled to delivery of 350,000 acre feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre-feet. (c) If the projected January 1 Lake Mead elevation is at or below 1,025 feet, then no delivery of EC ICS is permitted.

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Exhibit 7 The Metropolitan Water District of Southern California Local Resources Program Additional Groundwater Recovery Projects

ICS Category: Extraordinary conservation (EC) ICS Subcategory: Contaminated groundwater recovery

Term: Variable. Each LRP agreement has its own terms specific to the associated project. LRP agreements for groundwater projects are usually for 25 years. A number of agreements have expired. When an agreement expires, Metropolitan stops making incentive payments for that project, but the project continues producing water and reducing a demand on imported supplies. The LRP program establishes projects and once the agreement expires the ongoing costs are funded locally.

Project Description: The Local Resources Program (LRP) is a program by which Metropolitan provides financial support to its member agencies to implement groundwater recovery projects in its service area. Groundwater recovery projects treat degraded or contaminated groundwater, which would not otherwise be used by agencies, for potable purposes. Metropolitan established the LRP in 1982 to provide financial support to its member agencies to implement local projects that reduce demand on Metropolitan's imported water supplies. Local agencies can apply for LRP funding for groundwater recovery projects. Metropolitan then enters into an agreement with the local agency to pay for water produced by an individual project for a multi-year term. Metropolitan offers three LRP incentive payment options to choose from: sliding scale incentives up to $340 per acre-foot (AF) over 25 years, sliding scale incentives up to $475 per AF over 15 years, or fixed incentives up to $305 per AF over 15 years.

A typical groundwater recovery project includes a treatment plant, pump stations, storage reservoirs, and a connection to an existing potable water distribution system to deliver the treated groundwater to customers. The treatment level depends on the type of contamination or degradation and could include reverse osmosis, ion exchange, granulated activated carbon, or chemical and biological treatment process. Reverse osmosis is usually used to remove salt but it is capable of removing other contaminants. Ion exchange is usually used to remove nitrate and hardness from groundwater. Granular activated carbon can be used to remove organic material and heavy metals. Chemical or biological treatments are usually used to remove iron and manganese or other chemical or organic materials from groundwater.

Since 1988, Metropolitan has included 25 groundwater recovery projects in the LRP and has paid about $156 million for the production of about 924,000 AF of recovered water as shown in the table below.

-29- Final Plan for the Creation of EC JCS, Calendar Year 2019 Exhibit 7

Deliveries Number of Contract Yield Incentives to Date Project Type to Date Projects (acre-feet per year) (million dollars) (acre-feet) Groundwater 25 116,930 924,000 156 Recovery Note: These values represent Metropolitan payment for delivered water under LRP agreements. Some LRP agreements have expired and Metropolitan no longer makes payments, but those projects are still producing water. This table does not include ongoing yields for projects once the agreements expire as these are then considered local supplies.

Annual ICS Creation Amount: The amount of EC JCS that can be created during any year is limited to the amount of groundwater recovered in Metropolitan's service area. Attachment 1 contains a list of additional LRP groundwater recovery projects not covered under Existing Exhibit M, and in 2019, Metropolitan expects to recover up to 11,875 acre-feet of local groundwater. Metropolitan will, in tum, reduce its use of Colorado River water from the amount that USBR would otherwise approve by up to 11,875 acre-feet, thereby creating EC JCS. Absent this proposed creation of EC JCS, an amount of water equal to the proposed EC JCS would have been imported from the Colorado River.

Quantification Methodology: Groundwater recovery facilities treat degraded groundwater for potable purposes. The treated project water is delivered directly to the participating agency's potable water distribution system and comingled with other potable water sources to serve customers in the agency's service area. As required by contract, the project water is measured using a flow meter at the facility's effluent location to understand the amount of project water pumped into the agency's potable water distribution system. Participating agencies are then required to report these flow measurements to Metropolitan on a monthly basis as part of the invoicing process. Participating agencies report their measurements (in acre-feet) using an online system, email, or regular mail, depending on the program. These measurements are the means of quantifying the amount of groundwater recovered, and therefore the potential amount of Colorado River water use foregone, as a result of this component of the LRP. If a project funding agreement expires, Metropolitan will continue to obtain groundwater recovery data as long as the project is operational.

Verification Methodology: At the end of each fiscal year, Metropolitan verifies the amount of groundwater recovered through an annual reconciliation process in which Metropolitan reviews the metered production records and compares it to monthly invoices submitted during the fiscal year. In addition, Metropolitan periodically conducts an audit of agencies' records pertaining to groundwater recovery. Metropolitan will, as part of its JCS Certification Report, provide records to Reclamation for all of the groundwater recovery projects for which incentive payments have been provided.

-30- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 7

Certification: Section XI.G.3.D.1 of the Interim Guidelines states the following:

-31- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 7

(a) If the projected January 1 Lake Mead elevation is above 1,045 feet and at or below 1,075 feet, then the combined total delivery of EC ICS, Binational ICS, System Efficiency ICS and DCP ICS from Lake Mead to California Contractors shall be limited to 400,000 acre feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4 ), under such conditions Metropolitan is entitled to delivery of 350,000 acre-feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre feet. (b) If the projected January 1 Lake Mead elevation is above 1,025 feet and at or below 1,045 feet, then the combined total delivery of Extraordinary Conservation ICS, Binational ICS, System Efficiency ICS, DCP ICS, and the conversion of ICS to DCP ICS in Lake Mead for California Contractors shall be limited to 400,000 acre-feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4), under such conditions Metropolitan is entitled to delivery of 350,000 acre feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre-feet. (c) If the projected January 1 Lake Mead elevation is at or below 1,025 feet, then no delivery of EC ICS is permitted.

-32- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

Exhibit 8 The Metropolitan Water District of Southern California Local Resources Program Recycling Projects

ICS Category: Extraordinary conservation (EC) ICS Subcategory: Wastewater recycling

Term: Metropolitan established the Local Resources Program (LRP) in 1982. Each LRP agreement has its own terms specific to the associated project. LRP agreements for recycled water projects are usually for 25 years. A number of agreements have expired. When an agreement expires, Metropolitan stops making incentive payments for that project, but the project is funded locally and continues producing water and reducing a demand on imported supplies.

Project Description: As part of the LRP, Metropolitan provides financial support to its member agencies to implement water recycling projects in its service area. Water recycling projects treat municipal wastewater for beneficial uses outlined in Title 22 of the California Code of Regulations. A typical water recycling project includes a treatment plant, pump stations, storage reservoirs, and a distribution system to deliver the treated recycled water to end-users. The treatment level depends on the intended use. Tertiary treated recycled water can be utilized for non-potable uses such as landscape and agricultural irrigation, commercial and industrial uses, and groundwater recharge thorough spreading grounds. Advanced treated recycled water, using reverse osmosis or another treatment process, is needed for certain industrial uses, seawater barriers, and direct injections into groundwater. Recycled water for indirect potable uses such as surface water augmentation requires even further treatment.

Metropolitan established the LRP to implement local projects that reduce demand on Metropolitan's imported water supplies. Local agencies can apply for LRP funding for water recycling projects. Metropolitan enters into an agreement with local agencies to pay for water produced by an individual project for a multi-year term. Metropolitan offers three LRP incentive payment options to choose from: sliding scale incentives up to $340 per acre-foot (AF) over 25 years, sliding scale incentives up to $475 per AF over 15 years, or fixed incentives up to $305 per AF over 15 years.

Since 1982, Metropolitan has included 81 water recycling projects in the LRP and has paid about $475 million for the production of about 2.8 million acre-feet of recycled water as shown in the Table below. Attachment 2 to this Exhibit contains a complete list of LRP water recycling projects.

-33- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

Deliveries Number of Contract Yield Incentives to Date Project Type to Date Projects (acre-feet per year) (million dollars) (acre-feet) Water 81 312,000 2,760,000 475 Recycling Note: These values represent Metropolitan payment for delivered water under LRP agreements. Some LRP agreements have expired and Metropolitan no longer makes payments, but those projects are still producing water.

Annual ICS Creation Amount: The amount of EC ICS that can be created during any year is limited to the amount of recycled water produced in Metropolitan's service area. Metropolitan expects up to 311,653 acre-feet of recycled water to be produced at Metropolitan-funded facilities in its service area in 2019 (Attachment 2). Metropolitan will, in turn, reduce its use of Colorado River water from the amount that USBR would otherwise approve by up to 311,653 acre-feet, thereby creating EC ICS. Absent this proposed creation of EC ICS, an amount of water equal to the proposed EC ICS would have been imported from the Colorado River.

Quantification Methodology: Recycled water facilities treat municipal wastewater to a level suitable for delivery to individual customers for non-potable purposes such as irrigation, commercial and industrial. Each individual customer's delivery system includes a flow meter at a service connection to measure the amount of recycled water entering their system. Participating agencies are then required to report these flow measurements to Metropolitan on a monthly basis as part of the invoicing process. Participating agencies report their measurements (in acre-feet) using an online system, email, or regular mail, depending on the program. These measurements are the means of quantifying the amount of recycled water delivered, and therefore the potential amount of Colorado River water use foregone, as a result of this component of the LRP. If a project funding agreement expires, Metropolitan will continue to obtain recycled water delivery data as long as the project is operational.

Verification Methodology: At the end of each fiscal year, Metropolitan verifies the amount of recycled water produced by Metropolitan-funded facilities in its service area through an annual reconciliation process in which Metropolitan reviews the metered production records and compares it to monthly invoices submitted during the fiscal year. In addition, Metropolitan periodically conducts an audit of agencies' production and cost records pertaining to each project. Metropolitan will, as part of its ICS Certification Report, provide to USBR Metropolitan's verification file for all Metropolitan-funded water recycling projects.

-34- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

"Lower Basin Drought Contingency Operations" (LB Ops), Exhibit 1 to the "Lower Basin Drought Contingency Plan Agreement," which is itself Attachment B to the 2019 "Agreement Concerning Colorado River Drought Contingency Management and Operations" (collectively, the Drought Contingency Plan or DCP).

Section XI.G.3.B.4 of the Interim Guidelines specifies that California contractors may create up to 400,000 acre-feet of EC ICS in Lake Mead in any given year. Paragraph 1 of the California Agreement specifies that Metropolitan may create up to 400,000 acre-feet of EC-ICS in Lake Mead in any given year, less the amount of EC ICS created by Imperial Irrigation District (IID) in that year. Therefore, Metropolitan' s limitation to create EC ICS will be dependent upon the amount of EC ICS IID creates in 2019.

Certification: Section XI.G.3.D.1 of the Interim Guidelines states the following:

Delivery: Metropolitan does not anticipate delivery of any EC ICS in 2019. Delivery of EC ICS created by Metropolitan is limited by the requirements of LBOps, the Interim Guidelines, and the California Agreement. LBOps (Section IV .D) establishes the following limitations on delivery of EC ICS:

-35- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

(a) If the projected January 1 Lake Mead elevation is above 1,045 feet and at or below 1,075 feet, then the combined total delivery of EC ICS, Binational ICS, System Efficiency ICS and DCP ICS from Lake Mead to California Contractors shall be limited to 400,000 acre feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4), under such conditions Metropolitan is entitled to delivery of 350,000 acre-feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre feet. (b) If the projected January 1 Lake Mead elevation is above 1,025 feet and at or below 1,045 feet, then the combined total delivery of Extraordinary Conservation ICS, Binational ICS, System Efficiency ICS, DCP ICS, and the conversion of ICS to DCP ICS in Lake Mead for California Contractors shall be limited to 400,000 acre-feet in that year, as set forth in Section XI.G.3.C.4 of the 2007 Interim Guidelines. Per the California Agreement (paragraph 4), under such conditions Metropolitan is entitled to delivery of 350,000 acre feet of ICS from Lake Mead, plus up to an additional 50,000 acre-feet if delivery to all California Contractors otherwise does not equal 400,000 acre-feet. (c) If the projected January 1 Lake Mead elevation is at or below 1,025 feet, then no delivery of EC ICS is permitted.

-36- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

Attachment l

Existing Local Resources Program Additional Groundwater Recovery Projects

Contract Yield Project Name (AFY) Perris II Brackish Groundwater 5,500 Pomona Well #37-Harrison Well Groundwater Treatment 981 Glenwood Nitrate Water Reclamation 1,600 Juan Well Filter Facility 900 Westlake Wells-Tapia Water Reclamation Facility Intertie 150 Burbank Lake Street Granular Activated Carbon Treatment Plant 2,744 Total 11,875

-37- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

Attachment 2

Local Resources Program Recycled Water Projects

2019 Agreement Project Name Production Status (AFY) Active Alamitos Barrier Reclaimed Water Project 3,025

Active Anaheim Water Recycling Demonstration Project 110

Active Burbank Reclaimed Water System Expansion Project 850

Active Burbank Recycled Water System Expansion Phase II Project 960

Active Capistrano Valley Non Domestic Water System Expansion 1,011

Active Century I Rio Hondo Water Recycling Program 9,018

Active Development of Non-Domestic Water System in Ladera Ranch and 2,772 Talega Valley Active Direct Reuse Project Phase IIA 2,258

Active Dry Weather Runoff Reclamation Facility 210

Active Eastern Recycled Water Pipeline Reach 16 Project 820

Active El Toro Phase II Recycled Water Distribution System Expansion 350 Project Active El Toro Recycled Water System Expansion 1,175

Active Elsinore Valley Recycled Water Program 300

Active EMWD Recycled Water System Expansion Project 5,000

Active Encina Basin Water Reclamation Project Phases 1 and 2 5,000

Active Escondido Regional Reclaimed Water Project 993

Active Glendale Verdugo-Scholl and Brand Park Project 1,760

-38- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

2019 Agreement Project Name Production Status (AFY) Active Griffith Park South Water Recycling Project 450

Active Groundwater Reliability Improvement Program Recycled Water 10,000 Project Active Groundwater Replenishment System Project 70,000

Active Hansen Area Water Recycling Phase I Project 2,115

Active Hansen Dam Golf Course Water Recycling Project 500

Active Harbor Water Recycling Project 5,000

Active Lake Mission Viejo Advanced Purification WTF 300

Active Leo J. Vander Lans Water Treatment Facility Expansion Project 3,475

Active Long Beach Reclaimed Water Master Plan Phase I System 2,750 Expansion Active Los Angeles Taylor Yard Park Water Recycling Project 150

Active Michelson/Los Alisos Water Reclamation Plant Upgrades and 8,500 Distribution System Expansion Project Active Moulton Niguel Water Reclamation System 9,276

Active North Atwater Area Water Recycling Project 50

Active North City Water Reclamation Project 14,566

Active North Hollywood Area Water Recycling Project 300

Active Olivenhain Recycled Project - Southeast Quadrant 1,788

Active Otay Recycled Water System 7,062

Active Oxnard Advanced Water Purification Facility Project 2,310

Active Padre Dam MWD Reclaimed Water System Phase I 850

-39- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

2019 Agreement Project Name Production Status (AFY) Active Rancho California Reclamation Expansion Project 6,000

Active Rowland Water District Portion of the City of Industry Regional 1,017 Recycled Water Project Active San Clemente Recycled Water System Expansion Project 1,000

Active San Elijo Water Reclamation System 1,600

Active San Pasqual Water Reclamation Project, Phase I 1,100

Active Santa Maria Water Reclamation Project 400

Active Sepulveda Basin Sports Complex Water Recycling Project 350

Active Sepulveda Basin Water Recycling Project - Phase 4 445

Active Terminal Island Recycled Water Expansion Project 8,000

Active Trabuco Canyon Reclamation Expansion Project 800

Active USGVMWD Portion of the City of Industry Regional Recycled 2,234 Water Project Active Van Nuys Area Water Recycling Project 150

Active Walnut Valley Water District Portion of the City of Industry 2,135 Regional Recycled Water Project Active West Basin Water Reclamation Program 38,000

Active West Basin Water Recycling Program Phase V Project 8,000

Active Westside Area Water Recycling Project 150

Expired Calabasas Reclaimed Water System Extension Project 700

Expired Cerritos Reclaimed Water Extension Project 260

Expired Conejo Creek Water Recycling Project 14,000

-40- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

2019 Agreement Project Name Production Status (AFY) Expired Eastern Reach I, Phase II Reclaimed Water System 1,700

Expired Encina Water Pollution Control Facility Reclamation Project 165

Expired Fallbrook Public Utility District Water Reclamation Project 1,200

Expired Glendale Water Reclamation Expansion Project 500

Expired Green Acres Reclamation Project (Coastal) 320

Expired Green Acres Reclamation Project (OCWD) 2,160

Expired Green Acres Reclamation Project (Santa Ana) 320

Expired Irvine Reclamation Project 10,000

Expired Lakewood Water Reclamation Project 440

Expired Las Virgenes Reclamation - Triunfo County Sanitation District 2,700

Expired Long Beach Reclamation Project 1,700

Expired Los Angeles Greenbelt Project 900

Expired Oak Park/ North Ranch Recycled Water Distribution System 1,300

Expired Oceanside Water Reclamation Project 200

Expired Rincon Del Diablo Recycled Water Program 648

Expired San Clemente Water Reclamation Project 500

Expired Santa Margarita Water District Water Reclamation Expansion 3,600 Project Expired Sepulveda Basin Water Reclamation Project 1,500

Expired Shadowridge Water Reclamation Project 375

-41- Final Plan for the Creation of EC ICS, Calendar Year 2019 Exhibit 8

2019 Agreement Project Name Production Status (AFY) Expired South Laguna Reclamation Project 860

Expired Walnut Valley Water Reclamation Expansion Project 500

Expired Eastern Regional Reclaimed Water System 4,830

Expired IEUA Regional Recycled Water Distribution System 13,500

Expired San Vicente Water Recycling Project 340

Active and Total 311,653 Expired

-42- United States Department of the Interior BUREAU OF RECLAMATION Lower Colorado Regional Office P.O. Box 61470 Boulder City, NV 89006-1470 IN REPLY REFER TO: LC-4220 AUG 1 3 2019 2.2.4.23

CERTIFIED- RETURN RECEIPT REQUESTED

Mr. Roger K. Patterson Assistant General Manager The Metropolitan Water District of Southern California P.O. Box 54153 Los Angeles, CA 90054-0153

Subject: Approval of The Metropolitan Water District of Southern California' s (MWD) Calendar Year (CY) 2019 Extraordinary Conservation (EC) Intentionally Created Surplus (JCS) Plan of Creation

Dear Mr. Patterson:

The Bureau of Reclamation has received MWD's Plan for the Creation ofExtraordina,y Conservation Intentionally Created Surplus During Calendar Year 2019 (JCS Plan), originally submitted by letter dated January 2, 2019, and subsequently replaced by letter dated June 17, 2019. MWD' s ICS Plan was submitted in fulfillment of the requirements set forth in Section Xl.G.3.B of the 2007 Record of Decision for Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations.for Lake Powell and Lake Mead (2007 Interim Guidelines) regarding the requirements for the creation ofICS.

MWD' s JCS Plan describes the following activities from which MWD intends to create EC lCS in CY 2019:

(1) Palo Verde Irrigation District (PVID) Forbearance and Fallowing Program. (2) Imperial Irrigation District (IID) Water Conservation Program. (3) Water Supply from the Lower Colorado Water Supply Project (LCWSP). (4) Water Supply from Desalination. (5) Landscape Transformation Program. (6) Indoor Water Conservation Devices. (7) Local Resources Program Additional Groundwater Recovery Projects. (8) Local Resources Program Recycling Projects.

Activities (l ) through (4) are described in and incorporated as Exhibits G, H, L, and M, respecti vely, to the 2007 Lower Colorado River Basin intentionally Created Surplus Forbearance Agreement. Activities (5) through (8) are described in and incorporated as Lower Basin Drought Contingency Operations (LBOps) Exhibits X, Y, Z, and AA, respectively. 2

As noted in MWD's June 17th letter, MWD's ICS Plan is designed to maximize the state of California's ICS storage opportunities by seeking approval to create up to 450,000 acre-feet (AF) of EC ICS during CY 2019. Reclamation recognizes that Section IV.B of LBOps provides for the state of California to create additional amounts EC JCS above its 400,000 AF annual EC ICS creation limit, however, any such creation is contingent upon the Secretary of the Interior's authorization. Any EC ICS creation capacity available to the state of California in excess of its 400,000 AF limit will be determined based on final accounting records. The maximum total amount of EC ICS that may be created by the Lower Division States during any year will continue to be limited to 625,000 AF as set forth in Section XI.G.3.B.4 of the 2007 Interim Guidelines.

In accordance with the California Agreement for the Creation and Delivery ofExtraordinary Conservation Intentionally Created Surplus, as amended (California ICS Agreement), the amount of EC ICS creation capacity available to MWD will be limited to the amount that, when combined with the amount of EC ICS created by the Imperial Irrigation District (11D), does not exceed the maximum EC ICS creation capacity available to the state of California.

Reclamation has reviewed MWD's ICS Plan and confirms it contains all necessary information required by Section XI.G.3.B of the 2007 Interim Guidelines. In accordance with Section XI.G.7.B.5 of the 2007 Interim Guidelines, Reclamation has consulted with the Basin States regarding MWD's JCS Plan.

Based upon Reclamation's review of MWD's JCS Plan and the completion of the consultation process, I approve MWD's ICS Plan for the creation of up to 450,000 AF of EC ICS as provided in the table (and associated footnote) below.

Approved ICS Conservation Activity Creation Amount (AF) PVID Forbearance and Fallowing Program up to 49,301 IID Water Conservation Program up to 110,000 Water Supply from Desalination up to 129,874 Water Supply from the LCWSP up to 10,000 Landscape Transformation Program up to 34,125 Indoor Water Conservation Devices up to 91,383 Local Resources Program Additional Groundwater Recovery Projects up to 11,875 Local Resources Program Recycling Projects up to 311,653 Total EC ICS for CY 2019 up to 450,000 AF1 1ICS creation amount in excess of the state of California's 400,000 AF maximum annual limit is contingent upon authorization by the Secretary. In accordance with the California ICS Agreement, MWD's EC ICS creation amount will be dependent upon, among other factors, the amount of EC ICS created in CY 2019 by 11D. 3

Section XLG.3.B.1 of the 2007 Interim Guidelines provides that, subject to approval by Reclamation, MWD may modify its approved ICS Plan during the year of creation. In accordance with Section XI. G .3 .D .1 of the 2007 Interim Guidelines, MWD is required to submit a Certification Report to the Regional Director demonstrating the amount of ICS created and that the methods of creation were consistent with MWD's approved ICS Plan.

If you have questions, please contact Mr. Jeremy Dodds, Water Accounting and Verification Group Manager, at 702-293-8164 or [email protected].

Sincerely,

Terrance J. Fulp, Ph.D. Regional Director cc: Mr. Christopher S. Harris Mr. Thomas Buschatzke Executive Director Director Colorado River Board of California Arizona Department of Water Resources 770 Fairmont Avenue, Suite 100 P.O. Box 36020 Glendale, CA 91203 Phoenix, AZ 85067-6020

Mr. Eric P. Witkoski Ms. Rebecca Mitchell Executive Director Director Colorado River Commission of Nevada Colorado Water Conservation Board 555 East Washington Avenue, Suite 3100 1313 Sherman Street, Room 718 Las Vegas, NV 89101 Denver, CO 80203

Mr. Eric Millis Ms. Amy I. Haas Water Resources Director Executive Director/Secretary Utah Division of Water Resources Upper Colorado River Commission P.O. Box 146201 3 5 5 South 400 East Salt Lake City, UT 84114-6201 Salt Lake City, UT 84111

John R. D' Antonio Jr., P.E. Mr. Rick Deuell New Mexico State Engineer Wyoming State Engineer Office of the State Engineer Wyoming State Engineer's Office State of New Mexico Herschler Building, 2nd Floor West P.O. Box 25102 122 West 25 th Street Santa Fe, NM 87504-5012 Cheyenne, WY 82001

Mr. Theodore C. Cooke Tina Anderholt Shields, P .E. General Manager Water Department Manager Central Arizona Water Imperial Irrigation District Conservation District P.O. Box 937 P .0. Box 43020 Imperial, CA 92251-093 7 Phoenix,AZ 85080-3020

Continued on next page. 4 cc: Continued from previous page.

Mr. John Entsminger Mr. Charles B. Sherrill, Jr. General Manager Chairman Southern Nevada Water Authority Mohave Valley Irrigation and Drainage District 1001 South Valley View Boulevard, 1460 East Commercial Street MS480 Mohave Valley, AZ 86440 Las Vegas, NV 89153

Mr. Elston K. Grubaugh Mr. William Hasencamp Manager/Secretary Manager, Colorado River Resources Wellton-Mohawk Irrigation The Metropolitan Water District and Drainage District of Southern California 30570 Wellton-Mohawk Drive P.O. Box 54153 Wellton, AZ 85356 Los Angeles, CA 90054-0153

Honorable Dennis Patch Honorable Stephen R. Lewis Tribal Chairman Governor Colorado River Indian Tribes Gila River Indian Community 26600 Mohave Road P.O. Box 97 Parker, AZ 85344 Sacaton, AZ 85147-0097

CALENDAR YEAR 2019 FALLOWED LAND VERIFICATION REPORT

PVID/MWD Forbearance and Fallowing Program

Palo Verde Irrigation District, The Metropolitan Water District of Southern California, and U.S. Bureau of Reclamation

May 7, 2020 FINAL

CALENDAR YEAR 2019 FALLOWED LAND VERIFICATION REPORT PVID/MWD Forbearance and Fallowing Program

Executive Summary

On January 1, 2005, the Palo Verde Irrigation District (PVID) and The Metropolitan Water District of Southern California (MWD) implemented a 35-year “Forbearance and Fallowing Program” (Program) with landowners within PVID. There is a total of 25,947 acres enrolled in the Program. Participating landowners started fallowing on behalf of the Program on January 1, 2005. The Program is termed to end on July 31, 2040. The Program’s objective is to save water that would have been used to grow crops on the fallowed land but is alternatively made available to MWD. In July 2016, MWD issued a fallowing call for Contract Years 2017/18 and 2018/19 (August 1, 2017 through July 31, 2019) at 40% of the landowner’s maximum commitments. In July 2017, MWD did not issue a fallowing call for Contract Year 2018/19 and 2019/20 (August 1, 2018 through July 31, 2020). In July 2018, MWD issued a fallowing call for Contract Years 2019/20 and 2020/21 (August 1, 2019 through July 31, 2021) at 40% of the landowner’s maximum commitments. Due to these fallowing call issuances, for calendar year 2019, from January 1, 2019 through July 31, 2019, participating landowners fallowed their land at 40% of their maximum commitments. Then, from August 1, 2019 through December 31, 2019, the fallowing level continued at 40% of their maximum commitments. At the 40% fallowing level, the Program (for the first seven months) fallowed 10,376 acres. Starting August 1, 2019, fallowing continued at the 40% level of 10,376 acres. The Program’s average fallowing level for calendar year 2019 was 40% (10,376 acres). Through the act of fallowing, water use within PVID is reduced and hence water is saved. However, the actual amount of water saved is difficult to quantify. The types and acreage of crops that would have been grown on the fallowed lands, absent the Program’s existence, cannot be definitively known; hence estimating the actual amount of water savings created through the Program’s fallowing must use an alternate approach. Two methods were used to estimate the water savings. Under the first method (Historical Use Method), three periods of past years deemed representative of historical conditions in PVID were selected and irrigation water use rates during each period were calculated and used to estimate water savings from the fallowed lands for calendar year 2019. Under the second method (Actual Use Method), irrigation water use on irrigated agricultural lands during calendar year 2019 was calculated and was then used to estimate water savings on the fallowed fields. The resulting estimates of saved water by each method are shown in Table E-1.

Page 2 of 19

Table E-1: Estimates of Saved Water by Method – Calendar Year 2019

Method Saved Water (acre-feet) 12-Year Average (1988-2002)* 47,211 5-Year Average (1998-2002) 49,286 3-Year Average (2000-2002) 52,192 Actual Use Method – Calendar Year 2019 44,477 *1992, 1993 and 1994 data were not included in the analysis. From 1992 through 1994, the PVID-MWD Test Fallowing Program was conducted. Estimates of water saved by the Program in calendar year 2019 ranged from 44,477 acre-feet to 52,192 acre-feet. Based on the analyses described in Section 7.0, the Actual Use Method is considered a reasonable water conservation quantification method reflective of the agronomic, land ownership, weather, water use, and market conditions prevailing in the Palo Verde Valley during calendar year 2019 and was selected as the method used to quantify the water saved by the Program. As reflected in Table E-1, the resulting estimate of the amount of water saved during calendar year 2019 by the Program is 44,477 acre-feet.

Page 3 of 19

CALENDAR YEAR 2019 FALLOWED LAND VERIFICATION REPORT PVID/MWD Forbearance and Fallowing Program

Table of Contents Page Executive Summary ...... 2 Table of Contents ...... 4 1.0 Program Description ...... 5 2.0 Palo Verde Irrigation District ...... 5 3.0 The Metropolitan Water District of Southern California ...... 7 4.0 Program Implementation ...... 7 5.0 Saved Water ...... 10 6.0 Historical Use Method ...... 10 6.1 12-Year Average: 1988-2002 (Excluding 1992-94) ...... 11 6.2 5-Year Average: 1998-2002 ...... 13 6.3 3-Year Average: 2000-2002 ...... 13 7.0 Actual Use Method – Calendar Year 2019 ...... 14 8.0 Conclusions ...... 15

List of Tables

Table E-1 Estimates of Saved Water by Method – Calendar Year 2019 ...... 3 Table 1 Climatic Data, Palo Verde Valley, California – 1988-2019 ...... 6 Table 2 Fallowed Valley Lands – Calendar Year 2019 ...... 10 Table 3 Estimated Irrigation Water Use on Valley Lands – 1988-2002 ...... 11 Table 4 Farmed Acreage in Valley Portion of PVID – 1988-1991 & 1995-2002 12 Table 5 Estimated Irrigation Water Use Factors on Valley Lands – . 1988-2002 12 Table 6 Estimated Saved Water Using the 12-Year Average Method – Calendar Year 2019...... 13 Table 7 Estimated Irrigation Water Use Factors on Valley Lands – Calendar Year 2019 ...... 14 Table 8 Estimated Saved Water Using the Actual Use Method – Calendar Year 2019 ...... 15 Table 9 Estimates of Saved Water by Method – Calendar Year 2019 ...... 16

List of Attachments

Attachment 1 Fallowed Fields under the Program on 1/1/2019 ………………….. 17 Attachment 2 Fallowed Fields under the Program on 12/31/2019 ……………….. 18

Appendix A

Bureau of Reclamation’s Calendar Year 2019 Verification Reports …………… ... 19

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CALENDAR YEAR 2019 FALLOWED LAND VERIFICATION REPORT PVID/MWD Forbearance and Fallowing Program

1.0 Program Description On January 1, 2005, the Palo Verde Irrigation District (PVID) and The Metropolitan Water District of Southern California (MWD) initiated a 35-year “Forbearance and Fallowing Program” (Program) with landowners within PVID that would extend through July 31, 2040. Participation in the Program is voluntary but requires participating landowners to sign a 35-year participation contract. A total of 25,947 acres are enrolled in the Program. MWD paid participating landowners a one-time signup payment for enrolling their lands in the Program and fallow land in response to MWD’s annual fallowing calls. In addition, MWD compensates participating landowners with annual payments for fallowing land within PVID that is served with Priority 1 Colorado River water delivered by PVID. In return for the payments, the water that would have been used to grow crops on the fallowed lands is made available to MWD. 2.0 Palo Verde Irrigation District The Palo Verde Irrigation District Act was passed by the California Legislature in 1923. PVID was then organized and began functioning in 1925. Governance is by a 7-member Board of Trustees. Administration is a General Manager and a staff of 66, currently, not counting Board members. PVID presently covers about 189 square miles in Riverside and Imperial Counties of California. The principal city in PVID’s service area is Blythe, which within its urban and fringe area, has a population of about 21,800 people. Currently, PVID is approximately 131,285 acres with 104,485 acres located in the Palo Verde Valley (Valley) portion of PVID and 26,800 acres located on the adjacent Palo Verde Mesa (Mesa). PVID diverts water from the Colorado River, which is regulated by the U.S. Bureau of Reclamation (Reclamation). The Valley’s long, hot growing season is ideal for agriculture. Crops include vegetables, forage, grains and fibers. Mild winters, with a minimum of frost, permit the growing and harvesting of crops throughout the year.

Climatic data for temperature, precipitation, and evapotranspiration (ETo) in the Valley for the period 1988-2019 are shown in Table 1. The highest maximum annual average temperature was 93.03° Fahrenheit (F) in 2003; and the lowest minimum annual average temperature was 48.26° F in 2015. Annual rainfall ranged between a low of 0.42 inches in 2018 to a high of 6.49 inches in 1 1998 . Annual ETo varied between a low of 60.18 inches in 2017 at Palo Verde to a high of 79.32 inches in 1994 at Palo Verde.

1 California Irrigation Management Information System (CIMIS) stations #151, Ripley, and #175, Palo Verde II, rain gauges were off-line in 2015 and 2014 and 2015, respectively.

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Table 1: Climatic Data, Palo Verde Valley, California – 1988-2019

Maximum Minimum ETo Annual Annual Annual Eto Palo Eto Year Blythe Average Average Rainfall2 Verde3 Ripley5 NE4 Temperature1 Temperature1 (oF) (oF) (inches) (inches) (inches) (inches) 1988 88.5 57.1 3.53 72.3 1989 90.1 54.9 1.26 68.99 1990 88.2 56.3 1.66 73.04 1991 86.5 55.8 4.32 68.75 1992 87.5 58.6 6.21 70.47 1993 88.7 57.2 5.05 77.15 1994 88.5 57.4 3.4 79.32 1995 89.2 58.3 2.53 73.55 1996 90.1 59.6 2.34 73.53 1997 88.4 58.3 5.79 68.2 69.03 1998 86.5 56.8 6.49 68.42 66.71 1999 88.5 56.3 3.2 70.58 72.52 69.67 2000 89.4 58.6 0.72 68.81 69.13 67.22 2001 89.5 56.1 4.78 69.11 67.5 68.81 2002 89.2 57.2 0.76 71.09 72.41 69.34 2003 93.03 60.32 2.68 67.26 68.46 67.15 2004 91.9 59.55 2.57 66.78 66.64 67.69 2005 87.11 55.77 6.39 65.66 67.11 65.13 2006 90.5 57.9 1.57 69.6 75.5 67.9 2007 88.57 59.89 1.93 69.85 73.38 68.27 2008 89.65 57.48 2.41 71.47 73.69 68.18 2009 85.39 52.83 1.31 68.05 70.77 71.42 2010 84.58 54.08 2.56 64.72 72.42 67.02 2011 84.7 52.81 2.41 72.69 68.41 69.51 2012 86.39 54.11 3.36 66.70 67.60 65.05 2013 85.71 53.49 2.32 66.33 70.20 66.94 2014 86.95 54.63 3.316 67.57 71.70 69.51 2015 73.60 48.26 1.017 62.17 62.93 68.67 2016 85.53 52.81 2.90 68.08 72.00 77.15 2017 86.86 54.96 3.51 60.18 64.91 73.44 2018 86.27 54.79 0.42 71.54 N/A 68.74 2019 84.95 53.72 3.03 69.57 N/A 73.46 Average 87.52 56.12 2.99 69.42 69.67 69.06 1 National Oceanic and Atmospheric Administration (NOAA) data from Blythe Station except for October 1997; August, September, and November 1999; January and December 2000; December 2001; and October 2006 when NOAA values from Blythe Airport Station were used because of missing data. Starting 2009, data are averages of the three CIMIS stations at Palo Verde, Blythe, and Ripley. 2 Data through 2008 from NOAA Blythe Station, and starting in 2009, data are averaged from the three CIMIS stations at Palo Verde, Blythe, and Ripley. 3 Data from Palo Verde CIMIS station #72 for 1988-2000; and from Palo Verde II CIMIS station #175 for 2001 onward. 4 Data from Blythe Northeast CIMIS station #135. 5 Data from Ripley CIMIS station #151. 6 The CIMIS station #175 (in Palo Verde) rainfall gauge was off-line in 2014 and 2015. 7 The CIMIS station #151 (in Ripley) rainfall gauge was off-line in 2015.

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3.0 The Metropolitan Water District of Southern California MWD was incorporated in 1928 and currently has 26-member agencies. Governance is by a 38- member Board of Directors with each member agency entitled to be represented by one director with representation by additional directors being based on assessed valuation. Administration is a General Manager and a staff of currently 1,887 employees. MWD provides supplemental water supplies to its service area from two sources: 1) MWD’s Colorado River Aqueduct and 2) the Department of Water Resources’ State Water Project/California Aqueduct. Water is provided to approximately 18.9 million people in a service area of approximately 5,200 square miles, consisting of portions of Los Angeles, Orange, San Diego, Riverside, San Bernardino, and Ventura counties of California. MWD has increased its ability to supply water, particularly in dry years, through the implementation of storage, conservation, and transfer programs. On October 10, 2003, the United States, Imperial Irrigation District, Coachella Valley Water District, MWD, and San Diego County Water Authority executed the “Colorado River Water Delivery Agreement: Federal Quantification Settlement Agreement for purposes of Section 5(B) of the Interim Surplus Guidelines” (Delivery Agreement). Under the Delivery Agreement, MWD agreed that if consumptive use of Colorado River water in accordance with Priorities 1 and 2 of the contracts for delivery of Colorado River water in California, together with the use of Colorado River water on PVID Mesa lands in accordance with Priority 3(b), exceeds 420,000 acre-feet in a calendar year, the Secretary of the Interior (Secretary) will reduce the amount of water otherwise available to MWD, by the amount that such use exceeds 420,000 acre-feet. To the extent that the amount of water used in accordance with Priorities 1, 2, and 3(b) is less than 420,000 acre-feet in a year, the Secretary will deliver to MWD the difference. For the purposes of the Delivery Agreement, “consumptive use” means diversions from the Colorado River less such measured and unmeasured return flow thereto as are available for consumptive use in the United States or in satisfaction of the Mexican Treaty obligation. 4.0 Program Implementation Under the Program, MWD has the option to issue a yearly fallowing call to participating landowners a year in advance of the fallowing start date of August 1. Each fallowing call is for a two-year period and once issued, cannot be rescinded or diminished. In July 2016, MWD issued a fallowing call for Contract Years 2017/18 and 2018/19 (August 1, 2017 through July 31, 2019) at 40% of the landowner’s maximum commitments. In July 2017, MWD did not issue a fallowing call for Contract Year 2018/19 and 2019/20 (August 1, 2018 through July 31, 2020. In July 2018, MWD issued a fallowing call for Contract Years 2019/20 and 2020/21 (August 1, 2019 through July 31, 2021) at 40% of the landowner’s maximum commitments. Due to these fallowing call issuances, for calendar year 2019, from January 1, 2019 through July 31, 2019, participating landowners fallowed their land at 40% of their maximum commitments. Then, from August 1, 2019 through December 31, 2019, the fallowing level continued at 40% of their maximum commitments. The following graphics illustrate the calls at the 40% level for the first seven months and the 40% level for the remaining five months of calendar year 2019.

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January 1, 2019 - July 31, 2019 40% + 0% = 40% Fallowing

July 2017 Fallowing Call @ 0.0% No fallowing call issued for Contract Years 2018/19 & 2019/20 July 2016 Fallowing Call @ 40% Contract Years 2017/18 & 2018/19 August 1, 2017 – Juy 31, 2019 Time The above chart shows two fallowing calls that were issued in July 2016 and July 2017. The two lower horizontal bars represent the fallowing calls’ two Contract Years at the 40% level and the no fallowing call, i.e., 0.0%, respectively. The overlapping occurs when two Contract Years share the same time period, represented by the top horizontal bar. Within this shared Contract Year, calendar year 2019 begins, defined by the vertical dashed lines, representing the time period from January 1, 2019 to July 31, 2019.

August 1, 2019 - December 31, 2019 0 + 40% = 40% Fallowing

July 2018 Fallowing Call @ 40.0% Contracts Year 2019/20 & 2020/21 August 1, 2019 - July 31, 2021

July 2017 Fallowing Call @ 0.0% No fallowing call issued for Contract Years 2018/19 & 2019/20

Time Since MWD did not issue a fallowing call in July 2017, there is no 2nd contract year fallowing level. Therefore, the period from August 1, 2019 to December 31, 2019 is defined by the July 2018 fallowing call at 40% fallowing.

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Calendar Year 2019 January 1, 2019 - December 31, 2019 40% + 0% = 40% Fallowing 0% + 40% = 40% Fallowing

July 2018 Fallowing Call @ 40.0% Contract Year 2019/20 & 2020/21 August 1, 2019 - July 31, 2021

July 2017 Fallowing Call @ 0.0% No fallowing call issued for Contract Years 2018/19 & 2019/20 July 2016 Fallowing Call @ 40% Contract Years 2017/18 & 2018/19 August 1, 2017 – Juy 31, 2019 Time The above graphic summarizes the entire calendar year 2019 at 40% fallowing level. At 40% fallowing level, the Program (for the first seven months) fallowed 10,376 acres. Starting August 1, 2019, fallowing continued at the 40% level of 10,376 acres. The Program’s average fallowing level for calendar year 2019 was 40% (10,376 acres). Table 2 shows the fallowed acreage per month. Attachment 1 shows the fallowed fields as of January 1, 2019 and Attachment 2 shows the fallowed fields as of December 31, 2019. All of the fallowed acres designated by the participants were qualified by PVID for fallowing eligibility, i.e., entitled to receive Priority 1 water, had been irrigated, and a crop had been harvested at least once during the past five years. Following the designation of fallowed acreage, a MWD representative visited the field before the date fallowing was to commence, verified fallowing conditions had been met and took photographs as needed to document the fallow status of fields. The same procedure was followed when participants would make changes in the acreage and/or location of fallowed lands at various points in time during the year thus ensuring that only qualified land is being fallowed. In addition, Reclamation staff conducted semi-annual field inspections, in May and December 2019, to verify the status of fallowed fields under the Program. In each field inspection, approximately five percent of the total fallowed acreage was randomly selected and inspected, and the fallow status documented. Results of Reclamation’s field verification inspections are included in Appendix A.

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Table 2: Fallowed Valley Lands – Calendar Year 2019 At Start Average for Month of Month Month (Acres) (Acres) Jan 10,376 10,376 Feb 10,376 10,376 Mar 10,376 10,376 Apr 10,376 10,376 May 10,376 10,376 Jun 10,376 10,376 Jul 10,376 10,376 Aug 10,376 10,376 Sep 10,376 10,376 Oct 10,376 10,376 Nov 10,376 10,376 Dec 10,376 10,376

Yearly Average 10,376.0 10,376.0 5.0 Saved Water The purpose of the Program is to save water that would have been otherwise used for agricultural production in PVID. To estimate the amount of water saved, it is necessary to estimate the amount of water that would have been consumed on the fallowed lands had crops been produced. Through the act of fallowing, water use within PVID is reduced and hence water is saved. However, the actual amount of water saved is difficult to quantify. The types and acreage of crops that would have been grown on the fallowed lands, absent the Program’s existence, cannot be definitively known; hence estimating the actual amount of water savings created through the Program’s fallowing must use an alternate approach. Therefore, it was necessary to develop acceptable procedures to estimate the amount of saved water to the degree of accuracy allowed by available data. Two methods were used to estimate the amount of water saved during calendar year 2019. Under the first method (Historical Use Method), three periods of past years deemed representative of conditions in PVID were selected and estimated irrigation water use rates during each period were calculated and used to estimate water savings from the fallowed lands during calendar year 2019. Under the second method (Actual Use Method), irrigation water use on irrigated agricultural lands during calendar year 2019 was calculated and was then used to estimate water savings on the fallowed fields. 6.0 Historical Use Method Three historical periods were selected that were deemed representative of typical conditions in PVID when cropping practices were not influenced by outside factors such as an impending

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fallowing program or a return to irrigation following a fallowing program. The periods selected were: 12 years, 5 years, and 3 years; three separate analyses were conducted. 6.1 12-Year Average: 1988-2002 (Excluding 1992-94) The first period extends from 1988 through 2002, but excluded 1992, 1993, and 1994 because during August 1992 through July 1994, the PVID/MWD Test Fallowing Program affected water use and the cropped acreage during those three years. This adjustment left 12 years of data for the analysis. Diversions at the Palo Verde Diversion Dam were tabulated by month for each year in the analysis. The 12 data values for each month were averaged, and the resulting averages for each month were summed to determine the average annual diversion. Similarly, water deliveries to the PVID Mesa were tabulated by month. Diversions at the Palo Verde Diversion Dam were then reduced by measured returns, unmeasured returns, and deliveries to the Mesa. The resulting net diversions were used to estimate the amount of irrigation water use by crops grown in the Valley lands of PVID. Diversions and cropped acreage for lands upstream of the Palo Verde Diversion Dam were not included in the analysis. Table 3 shows the tabulation for each month, which when summed, results in an estimated average annual crop water use of 400,512 acre-feet.

Table 3: Estimated Irrigation Water Use on Valley Lands – 1988–20021 (acre-feet)

Measured & Estimated Irrigation Gross Deliveries Month Unmeasured Water Use on Diversions to Mesa Return Flows2 Valley Lands

Jan 31,460 30,191 210 1,059 Feb 52,419 32,927 403 19,089 Mar 71,357 38,837 639 31,881 Apr 87,610 41,522 948 45,140 May 102,507 46,644 1,169 54,694 Jun 109,957 48,197 1,273 60,487 Jul 116,762 50,094 1,371 65,297 Aug 108,093 52,536 1,385 54,172 Sep 79,391 48,362 987 30,042 Oct 65,820 45,938 787 19,095 Nov 49,483 40,725 528 8,230 Dec 51,782 39,908 548 11,326 Yearly Average 926,641 515,881 10,248 400,512 1 1992, 1993 and 1994 data were not included due to the 1992-94 PVID-MWD Test Fallowing Program. This reduced the data series to 12 years. 2 Source of Gross Diversions and Measured and Unmeasured Return Flows data is Reclamation records. Source of Deliveries to Mesa data is PVID records. Over the same 12-year period of data, the irrigated acreage on Valley lands averaged 88,053 water toll acres (Table 4). Dividing the estimated average annual irrigation water use of 400,512 acre-feet by 88,053 water toll acres resulted in an estimated average annual irrigation water use of 4.55 acre-feet per water toll acre. The next step is to extrapolate the irrigation water use per acre estimate to the fallowed lands in calendar year 2019.

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Table 4: Farmed Acreage in Valley Portion of PVID – 1988-1991 and 1995-20021 Cropped Land Cropped Land Cropped Land Year (water toll acres) Year (water toll acres) Year (water toll acres) 1988 87,086 1995 88,243 1999 88,910 1989 86,701 1996 88,721 2000 88,709 1990 86,561 1997 88,645 2001 88,901 1991 86,601 1998 88,921 2002 88,633 Average 88,053 1 1992, 1993, and 1994 farmed acres are not included due to the 1992-94 PVID-MWD Test Fallowing Program; 2003 farmed acreage is not included due to the Coachella Valley Water District Fallowing Program; and 2004- 2017 farmed acreages are not included due to the current PVID-MWD Fallowing Program. Source: PVID records. The estimated values of monthly irrigation water use on Valley lands shown in Table 3 were converted to percentages of the yearly total as shown in Table 5. Applying the resulting monthly percentages to the average annual irrigation use estimate of 4.55 acre-feet per water toll acre resulted in an estimate of the monthly irrigation water use factors on Valley lands. These estimated monthly irrigation water use factors on Valley lands were used to provide a reasonable estimate of saved water by fallowed fields in PVID during calendar year 2019. Table 5: Estimated Irrigation Water Use Factors on Valley Lands – 1988-20021 Estimated Irrigation Estimated Irrigation Percent of Water Use on Water Use Factors on Month Yearly Total Valley Lands Valley Lands (%) (acre-feet) (acre-feet/acre) Jan 1,059 0.264412 0.012031 Feb 19,089 4.766149 0.216860 Mar 31,881 7.960061 0.362183 Apr 45,140 11.270574 0.512811 May 54,694 13.656020 0.621349 Jun 60,487 15.102419 0.687160 Jul 65,297 16.303382 0.741804 Aug 54,172 13.525687 0.615419 Sep 30,042 7.500899 0.341291 Oct 19,095 4.767647 0.216928 Nov 8,230 2.054870 0.093497 Dec 11,326 2.827880 0.128669 Total 400,512 100 4.55 1 Data for 1992, 1993 and 1994 were not included. From 1992 through 1994, the PVID- MWD Test Fallowing Program was conducted. This reduced the data series to 12 years. For each field participating in the Program in calendar year 2019, landowners provided PVID/MWD with the location of the fields they planned to fallow and the date when fallowing would begin. PVID/MWD recorded the information from each landowner into a database, located the fallowed land on maps, and inspected the land to verify the land was fallow on the date indicated by the landowner. This procedure assured appropriate accounting for and verification of the number of fallowed acres. The number of fallowed acres during each month in calendar year 2019 was determined from the database, resulting in 12 separate time periods during the year (Table 6). The monthly factors, as

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discussed above, were multiplied by the number of average monthly fallowed acres during the corresponding time period to estimate the corresponding amount of saved water. Table 6: Estimated Saved Water Using the 12-Year Average Method – Calendar Year 2019

Estimated Monthly Irrigation Water Saved Water Average of Month Use Factors on Cumulative Fallowed Lands Valley Lands (acre-feet) (water toll acres) (acre-feet/acre) Jan 0.012031 10,376 125 Feb 0.216860 10,376 2,375 Mar 0.362183 10,376 6,133 Apr 0.512811 10,376 11,454 May 0.621349 10,376 17,901 Jun 0.687160 10,376 25,031 Jul 0.741804 10,376 32,728 Aug 0.615419 10,376 39,114 Sep 0.341291 10,376 42,655 Oct 0.216928 10,376 44,905 Nov 0.093497 10,376 45,876 Dec 0.128669 10,376 47,211 Average for Year 10,376 Total for Year 4.55 47,211 For example, for the month of January, the average of 10,376 water toll acres was verified to be fallowed under the Program. Based on the 12 years of historical data, 0.264412% of the total annual irrigation water use on Valley lands occurred in January. Multiplying 0.00264412 by 4.55 acre-feet/acre resulted in 0.012031 acre-feet/acre, the average quantity of irrigation water used by each water toll acre during January. Multiplying the average quantity of irrigation water used by each water toll acre in January by the 10,376 water toll acres of fallowed land in January resulted in an estimated water savings for January of 125 acre-feet. This same procedure was applied to the fallowed acreage for all 12 months during calendar year 2019 and resulted in an estimated 47,211 acre-feet of saved water. 6.2 5-Year Average: 1998-2002 The 5-year historical use was based on PVID data for the period 1998 through 2002. The procedure used to calculate the estimated water saved from fallowing Valley lands during calendar year 2019 was the same as that applied in computing the 12-year historical use estimates. The 5-year historical use method yielded an estimated irrigation water use of 4.75 acre-feet/acre and 49,286 acre-feet of saved water during calendar year 2019. 6.3 3-Year Average: 2000-2002 The 3-year historical use method was based on PVID data for the period 2000 through 2002. Following the same procedure as used for the other historical periods, computations based on the 3-year historical use resulted in an estimated irrigation water use of 5.03 acre-feet/acre and 52,192 acre-feet of saved water during calendar year 2019.

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7.0 Actual Use Method – Calendar Year 2019 Under the actual use method, agricultural irrigation water use and acreage data from PVID and Reclamation records for calendar year 2019 were used to estimate the amount of saved water. Specifically, to estimate the amount of irrigation water consumptively used by the Valley lands under agricultural production, PVID’s total consumptive use (calculated as total diversions, less measured and unmeasured returns) was reduced by: (1) consumptive use by the habitat restoration and duck pond areas within the Palo Verde Ecological Reserve (Reserve); (2) consumptive use by the Dennis Underwood Conservation Area (Conservation Area); (3) consumptive use by lands upstream of the Palo Verde Diversion Dam; and (4) deliveries to the Mesa. Based on information provided by PVID, there were a total of 86,936 water toll acres in the Valley portion of PVID that could have received water for agricultural production. After subtracting the number of fallowed acres from this value, the resulting number of acres actually irrigated in the Valley portion of PVID was determined (on a monthly basis), as shown Table 7 below. Estimated monthly irrigation water use on Valley lands was divided by the average number of water toll acres in production on Valley lands for each month and summed for the 12 months, resulting in an estimated annual irrigation use of 4.29 acre-feet per acre (Table 7).

Table 7: Estimated Irrigation Water Use Factors on Valley Lands – Calendar Year 20191

Consumptive Estimated Estimated Irrigated PVID Conservation Use by Lands Irrigation Reserve Irrigation Valley Total Area Above Deliveries Water Use Consumptive Water Use Lands Month Consumptive Consumptive The to Mesa Factors on Use on Valley (water Use Use Diversion (acre-feet) Valley Lands (acre-feet) Lands toll (acre feet)2 (acre-feet) Dam (acre- (acre-feet) acres) (acre-feet) feet/acre)

Jan -1,195 190 0 45 671 (2,101) 76,560 (0.027443) Feb 16,913 224 0 56 813 15,820 76,560 0.206635 Mar 35,311 380 0 76 914 33,941 76,560 0.443325 Apr 38,197 521 13 83 1,100 36,480 76,560 0.476489 May 47,365 1,009 16 101 1,218 45,021 76,560 0.588049 Jun 52,489 1,057 17 122 1,297 49,996 76,560 0.653030 Jul 61,567 986 17 134 1,660 58,770 76,560 0.767633 Aug 53,666 634 15 128 1,717 51,172 76,560 0.668391 Sep 39,763 484 12 101 1,743 37,423 76,560 0.488806 Oct 15,835 364 8 85 1,242 14,136 76,560 0.184639 Nov 243 226 3 60 1,227 (1,273) 76,560 (0.016627) Dec -9,797 161 8 59 1,181 (11,206) 76,560 (0.146369) Total 350,357 6,236 109 1,050 14,783 328,179 4.286558 for Year Yearly 76,560 Average 1 Source: PVID and Reclamation records. 2 Values reflect PVID’s total consumptive use as reported in Reclamation’s 2019 Colorado River Accounting and Water Use Report: Arizona, California, and Nevada. Available at: https://www.usbr.gov/lc/region/g4000/wtracct.html.

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The same procedure used in Table 6 was followed to develop Table 8. Estimated monthly irrigation water use factors were multiplied by the fallowed acres for each month to estimate the monthly water savings resulting in a total of 44,477 acre-feet of water saved during calendar year 2019. Table 8: Estimated Saved Water Using the Actual Use Method – Calendar Year 2019

Estimated Monthly Average Saved Irrigation Water of Fallowed Water Month Use Factors on Lands Cumulative Valley Lands (water toll acres) (acre-feet) (acre-feet/acre) Jan (0.027443) 10,376 -285 Feb 0.206635 10,376 1,859 Mar 0.443325 10,376 6,459 Apr 0.476489 10,376 11,403 May 0.588049 10,376 17,505 Jun 0.653030 10,376 24,281 Jul 0.767633 10,376 32,246 Aug 0.668391 10,376 39,181 Sep 0.488806 10,376 44,253 Oct 0.184639 10,376 46,169 Nov (0.016627) 10,376 45,996 (0.146369) 44,477 Dec 10,376 Average for year 10,376 Total for Year 4.286558 44,477

8.0 Conclusions Two methods were used to estimate the amount of saved water during calendar year 2019: a historical use method and an actual use method. Three historical periods were used covering 12- year, 5-year and 3-year periods. The 12-year historical use method estimated a yearly irrigation water use of 4.55 acre-feet/acre, the 5-year historical use method estimated a yearly irrigation water use of 4.75 acre-feet/acre, and the 3-year historical use method estimated a yearly irrigation water use of 5.03 acre-feet/acre. Compilation of actual crop and agricultural irrigation water use data for calendar year 2019 in PVID resulted in an estimated irrigation use of 4.29 acre-feet per acre. Estimates of saved water for calendar year 2019 are shown in Table 9 and ranged from 44,477 acre-feet to 52,192 acre-feet.

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Table 9: Estimates of Saved Water by Method – Calendar Year 2019

Method Saved Water (acre-feet) 12-Year Average (1988-2002)* 47,211 5- Year Average (1998-2002) 49,286 3- Year Average (2000-2002) 52,192 Actual Use Method - CY 2019 44,477 *1992, 1993 and 1994 data were not included in the analysis. From 1992 through 1994, the PVID-MWD Test Fallowing Program was conducted. Based on the analyses described in Section 7.0, the Actual Use Method is considered a reasonable water conservation quantification method reflective of the agronomic, land ownership, weather, water use, and market conditions prevailing in the Palo Verde Valley during calendar year 2019, and was selected as the method used to quantify the water saved by the Program. As reflected in Table 9, the resulting estimate of the amount of water saved during calendar year 2019 by the Program is 44,477 acre-feet.

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Attachment 1 – Fallowed Fields under the Program on 1/1/2019

Metropolitan Water Odtrkt Fa.Uowlng Protram Pa.lo V.rde Irrigation Dlatriet

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44• A~• 35 YR FALLOW PROGRAM 10,376 ACRES ...... ,.

Fallow Fields ] CA TOWNSHIP, RANGE, AND SECTION SELECTION Sat Image Ht\ .... High : 254

Low : O

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Attachment 2 – Fallowed Fields under the Program on 12/31/2019

Mt!tropolitan W.ater Olttrict F.aUowtng Program 1Palo Verde krigatlon Otstricl ·:::::1· I .. .0 u

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35 YR FALLOW PROGRAM 10,376 ACRES ...... Fallow Fields L CA TOWNSHIP, RANGE, AND SECTION SELECTION Sat Image fM..-. High : 254

Low : 0

12-31 -2019

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Appendix A: Bureau of Reclamation’s Calendar Year 2019 Verification Reports

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Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program Verification Report May 2019

In accordance with its 2019 Plan (ICS Plan) for the Creation of Extraordinary Conservation Intentionally Created Surplus (ICS), the Metropolitan Water District of Southern California (MWD) is conducting its Forbearance and Fallowing Program (Program) with the Palo Verde Irrigation District (PVID) to create Extraordinary Conservation ICS during calendar year 2019.

In accordance with provisions within MWD’s ICS Plan, and to ensure the Program is being implemented as described in the Plan, Reclamation conducts semi-annual verification inspections on randomly selected fields amounting to 5 percent of the total acreage being fallowed during the current year. The first inspection for calendar year 2019 occurred on May 7th, 2019. Twenty-two (22) fields or parcels (partial fields) totaling 520 acres, representing five (5) percent of the fallowed lands in 2019, were inspected by a Reclamation inspector accompanied by two PVID employees. Documentation of the findings of the inspection are contained in this verification report.

A: Forbearance and Fallowing Program Verification General Observations: Trace vegetation was viewed on some fields, attributable to district-wide rainfall. Program participants, pursuant to environmental mitigation requirements for potential air quality impacts, can be required to implement dust control Best Management Practices (BMPs) by leaving vegetation residue on the field or seeding a cover crop prior to the fallowing start date. This was the case with several inspected fields. Fallow conditions were evident on every field inspected.

Field-specific Observations:

1. Fallowing Program Field No. 65367-004. PVID Parcel No. 803014. Reclamation Field No. 6626. Canal & Gate No. C03-42W & C03-13-3E. Acres: 16. Start Date: August 1, 2014 (will be rotating back into agricultural production on August 1, 2019, to satisfy the no more than 5 consecutive contract years condition set forth in Section 3.7.7 of the August 18, 2004 Forbearance and Fallowing Agreement.) Field Condition: Fallow; bare soil. Photo No.1. Comment: 16-acre parcel of 37-acre field which is approximately the middle third of the field.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program May 2019 Verification Report

2 2. Fallowing Program Field No. 65354-976. PVID Parcel No. 434010. Reclamation Field No. 4113. Canal & Gate No. C03-14-6W. Acres: 23. Start Date: August 1, 2016.

Field Condition: Fallow; bare soil.

Photo No. 2.

Comment: All of the 24-acre field except for a 1-acre strip along extreme East side. Looking West.

3. Fallowing Program Field No. 65366-001. PVID Parcel No. 425003. Reclamation Field No. 6231. Canal & Gate No. C10-11S. Acres: 5. Start Date: August 1, 2015.

Field Condition: Fallow; bare soil.

Photo No. 3.

Comment: Fallow area includes the foreground in photo. Looking East.

4. Fallowing Program Field No. 65359-035. PVID Parcel No. 506008. Reclamation Field No. 6061. Canal & Gate No. E-11W. Acres: 14. Start Date: August 1, 2015.

Field Condition: Fallow; bare soil with some desiccated weeds and some green weeds.

Photo No. 4.

Comments: Sprayed with herbicide last week. Looking West.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program May 2019 Verification Report 3 5. Fallowing Program Field No. 63907-299. PVID Parcel No. 731002. Reclamation Field No. 3680. Canal & Gate No. J02-12S. Acres: 38. Start Date: August 1, 2015.

Field Condition: Fallow, bare soil.

Photo No. 5.

Comment: West 38 acres. Looking Northeast.

6. Fallowing Program Field No. 63941-004. PVID Parcel No. 733007. Reclamation Field No. 3665. Canal & Gate No. K-7E Acres: 77. Start Date: August 1, 2014.

Field Condition: Fallow; crop stubble.

Photo No. 6.

Comment: All of 85-acre field except for narrow strip along the North edge. Looking East.

7. Fallowing Program Field No. 65029-021. PVID Parcel No. 535024. Reclamation Field No. 6186. Canal & Gate No. D10-4-2S. Acres: 10. Start Date: August 1, 2015.

Field Condition: Fallow; bare soil.

Photo No. 7.

Comment: East 10 acres of 47-acre field.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program May 2019 Verification Report 4 8. Fallowing Program Field No. 63900-010. PVID Parcel No. 610008. Reclamation Field No. 5566. Canal & Gate No. D10-13-49W. Acres: 18. Start Date: August 1, 2014.

Field Condition: Fallow; bare soil.

Photo No. 8.

Comment: West 18 acres of 25-acre field.

9. Fallowing Program Field No. 63921-004. PVID Parcel No. 809022. Reclamation Field No. 4485. Canal & Gate No. C03-15-10S. Acres: 11. Start Date: July 15, 2016.

Field Condition: Fallow; bare soil.

Photo No. 9.

Comment: North 11-acre portion of 20-acre field. Looking Southeast.

10. Fallowing Program Field No. 63909-002. PVID Parcel No. 808008. Reclamation Field No. 4155 Canal & Gate No. C03-16-6N. Acres: 5 Start Date: August 1, 2014.

Field Condition: Fallow; bare soil.

Photo No. 10.

Comment: 5-acre strip in 16-acre field.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program May 2019 Verification Report 5 11. Fallowing Program Field No. 65378-005. PVID Parcel No. 814009. Reclamation Field No. 6590 Canal & Gate No. WC2-1-0N. Acres: 6. Start Date: August 1, 2018.

Field Condition: Fallow; bare soil.

Comment: Took photo but evidently failed to execute “Submit” command.

12. Fallowing Program Field No. 65035-026. PVID Parcel No. 823009. Reclamation Field No. 4877. Canal & Gate No. C13-8W. Acres: 37. Start Date: August 1, 2014.

Field Condition: Fallow; bare soil.

Photo No. 11.

13. Fallowing Program Field No. 63928-014. PVID Parcel No. 905003. Reclamation Field No. 6102. Canal & Gate No. D10-11-54S. Acres: 10. Start Date: December 21, 2017.

Field Condition: Fallow; bare soil.

Photo No. 12.

Comment: Field was citrus trees previously. North 10-acre strip of 64-acre field.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program May 2019 Verification Report 6 14. Fallowing Program Field No. 63903-015. PVID Parcel No. 013008. Reclamation Field No. 5063. Canal & Gate No. D23-1-14W & D23-1-21N. Acres: 28. Start Date: December 10, 2017.

Field Condition: Fallow; bare soil with a few green weeds scattered across the field.

Photo No. 13.

Comment: Photograph looking Southwest.

15. Fallowing Program Field No. 63903-014. PVID Parcel No. 013001. Reclamation Field No. 6502. Canal & Gate No. D23-1-21N. Acres: 50. Start Date: October 1, 2017.

Field Condition: Fallow; bare soil.

Photo No. 14.

Comment: Looking Southeast.

16. Fallowing Program Field No. 65382-965. PVID Parcel No. 321004. Reclamation Field No. 5407. Canal & Gate No. D23-1-65W. Acres: 8. Start Date: August 1, 2014.

Field Condition: Fallow; bare soil.

Photo No. 15.

Comment: Looking Northwest.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program May 2019 Verification Report 7 17. Fallowing Program Field No. 63907-159. PVID Parcel No. 034011. Reclamation Field No. 5562. Canal & Gate No. C25-2N. Acres: 38. Start Date: August 1, 2015.

Field Condition: Fallow; bare soil.

Photo No. 16.

Comment: Recently disked. Looking Northeast.

18. Fallowing Program Field No. MET-142. PVID Parcel No. 032001. Reclamation Field No. 5001. Canal & Gate No. C24-8W. Acres: 39. Start Date: April 19, 2019.

Field Condition: Fallow; crop residue.

Photo No. 17.

Comment:

19. Fallowing Program Field No. 65386-022. PVID Parcel No. 304003. Reclamation Field Nos. 5636. Canal & Gate No. C03-171W. Acres: 6. Start Date: August 1, 2016.

Field Condition: Fallow; crop residue.

Photo No. 18.

Comment:

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program May 2019 Verification Report 8 20. Fallowing Program Field No. 63945-026. PVID Parcel No. 925012. Reclamation Field No. 5950. Canal & Gate Nos. C03-152W. Acres: 27. Start Date: August 1, 2014.

Field Condition: Fallow, bare soil, recently disked.

Photo No. 19.

Comment: Bare, disked soil.

21. Fallowing Program Field No. 65354-801. PVID Parcel No. 924020. Reclamation Field No. 5285. Canal & Gate No. C03-143W. Acres: 39. Start Date: August 1, 2017.

Field Condition: Fallow; bare soil.

Photo No. 20.

Comment:

22. Fallowing Program Field No. 63922-004. PVID Parcel No. 832002. Reclamation Field No. 4493 & 4090. Canal & Gate No. C03-11-1-2S. Acres: 15. Start Date: August 1, 2018.

Field Condition: Fallow; crop residue.

Photo No. 21.

Comment: Looking East.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program May 2019 Verification Report 9

Total acres inspected and verified as fallow during this field verification inspection visit: 520 acres within 22 parcels.

Based on the observations made and the information collected during the field verification inspection, the implementation of the extraordinary conservation measures noted above is:

181Confirmed • Unconfirmed

June 3. 2019 Date

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Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program May 2019 Verification Report Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program Verification Report December 2019

In accordance with provisions within MWD's ICS Plan, and to ensure the Program is being implemented as described in the Plan, Reclamation conducts semi-annual verification inspections on randomly selected fields amounting to 5 percent of the total acreage being fallowed during the current year. The second inspection for calendar year 2019 occurred on December 12th, 2019. Twenty-five (25) fields or parcels (partial fields) totaling 543 acres, representing five (5) percent of the fallowed lands in 2019, were inspected by Troy Wirth, Reclamation inspector acc~mpanied by Paula Hayden, PVID employee. Documentation of the findings of the inspection are contained in this verification report.

General Observations: Trace vegetation was viewed on some fields, attributable to district-wide rainfall. Program participants, pursuant to environmental mitigation requirements for potential air quality impacts, can be required to implement dust control Best Management Practices (BMPs) by leaving vegetation residue on the field or seeding a cover crop prior to the fallowing start date. This was the case with several inspected fields. Fallow conditions were evident on every field inspected.

Field-specific Observations:

I. Fallowing Program Field No. 63901-002. PVID Parcel No. 509022. Reclamation Field No. 4430 Canal & Gate No. UC-24E. Acres: 27. Start Date: August I, 2019.

Photo No.I. Comment: Photo taken from Southwest comer of field looking Northeast towards 4th Avenue.

Metropolitan Funded Palo Verde lnigation District Forbearance and Fallowing Program December 2019 Verification Report 2 2. Fallowing Program Field No. 63897-003. 3. PVID Parcel No. 522007. 4. Reclamation Field No. 3769. 5. Canal & Gate No. Dl0-6S. Photo No. 2 here is used for Inspection Parcels 2, 3, 4 & 5

Inspection Parcel No. 2 Acres: 5. Start Date: August 1, 2015. Field Condition: Fallow; bare soil and some weeds. Comment: This field has multiple fallow contracts on it. This 5-acre parcel is the extreme North edge of the field (showing up in the field as the right segment of the field. The photo is looking to the West.

Inspection Parcel No. 3 Acres: 1. Start Date: August 1, 2018. Field Condition: Fallow; bare soil with some desiccated weeds and some green weeds. Comment: Same field. Looking West. Fallow area in this photo is one-acre strip that is about ¾ of the way south from the north edge of the field.

Inspection Parcel No. 4 Acres: 5. Start Date: August 1, 2015. Field Condition: Fallow; bare soil with some desiccated weeds and some green weeds. Comments: Photo taken at East end looking West. Fallow area is 5-acre strip near the South edge of the field (left edge of the photo) that extends the length of the field. Inspection Parcel No. 5. Acres: 2. Start Date: August 1, 2015. Field Condition: Fallow; bare soil with some desiccated weeds and some green weeds. Comment: Photo taken at East end looking West. This 2-acre parcel is the extreme South edge of the field (showing up in the field as the left segment of the field bordering the alfalfa field.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program December 2019 Verification Report 3 6. Fallowing Program Field No. 63895-005. PVID Parcel No. 803009. Reclamation Field No. 33173 Canal & Gate No. C03-42E Acres: 10. Start Date: October I, 2018.

Field Condition: bare soil. There had been a recent rainstorm event as evidenced in the photograph.

Photo No. 6.

Comment: Looking North.

7. Fallowing Program Field No. 63902-001. PVID Parcel No. 816011. Reclamation Field No. 3610. Canal & Gate No. C03-65W. Acres: 26. Start Date: November 20, 2018.

Field Condition: Fallow; bare soil.

Photo No. 7.

Comment: Photo taken in NE corner looking to the SW.

8. Fallowing Program Field No. 63898-010. PVID Parcel No. 61700 I. Reclamation Field No. 6590. Canal & Gate No. D21-2W. Acres: 22. Start Date: August I, 2015.

Field Condition: Fallow; bare soil.

Photo No. 8.

Comment: Photo taken on West side of field a short distance North of the South edge of the field, looking South.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program December 2019 Verification Report 4 9. Fallowing Program Field No. 63898-054. PVID Parcel No. 824018. Reclamation Field No. 4202. Canal & Gate No. C-73W. Acres: 11. Start Date: August 1, 2019.

Field Condition: Fallow; bare soil.

Photo No. 9.

Comment: Photo taken in Northeast comer of 20-acre field. The fallow portion of the field is the North I I -acre portion of the 20-acre field. Looking Southeast.

10. Fallowing Program Field No. 63898-01 l. PVID Parcel No. 629008. • Reclamation Field No. 4953 . Canal & Gate No. DI l l S Acres: 30 Start Date: August I, 20 I 9.

Field Condition: Fallow; bare soil.

Photo No. IO.

Comment: Photo taken in the Northwestern comer of this 30-acre triangular field.

11. Fallowing Program Field No. 638988-043. PVID Parcel No. 628007. Reclamation Field No. 4320 Canal & Gate No. DI0-11-33W. Acres: 63. Start Date: August I, 2019.

Field Condition: Fallow; bare soil.

Photo No. 11.

Comment: Photo taken at SW comer of fallowed field

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program December 2019 Verification Report 5 12. Fallowing Program Field No. 63898-026. PVID Parcel No. 627002. Reclamation Field No. 4320. Canal & Gate No. DIO-l l-2-26W. Acres: 29. Start Date: August l, 2016.

Field Condition: Fallow; bare soil.

Photo No. 12.

Comment: Northeast comer of field looking to the Southwest. 29 acres fallowed. Note tumble weeds in the ditch.

13. Fallowing Program Field No. 63898-026. PVID Parcel No. 627002. Reclamation Field No. 4054. Canal & Gate No. Dl0-l l-2-26W. Acres: 44. Start Date: August l, 2016.

Field Condition: Fallow; bare soil.

Photo No. 13.

Comment: Photo taken at NW comer of field looking to the South.

14. Fallowing Program Field No. 63898-033. PVID Parcel No. 633002. Reclamation Field No. 4969. Canal & Gate No. Dl0-l l-43E. Acres: 48. Start Date: August 1, 2016.

Field Condition: Fallow; bare soil.

Photo No. 14.

Comment: Photograph taken in SW comer of 48-acre field looking to the North and East.

Metropolitan Funded Palo Verde lnigation District Forbearance and Fallowing Program December 2019 Verification Report 6

15. Fallowing Program Field No. 63898-033. PVID Parcel No. 633002. Reclamation Field No. 5760. Canal & Gate No. DI0-1 l-43E. Acres: 54 Start Date: August I, 2019.

Field Condition: Fallow; bare soil.

Photo No. 15.

Comment: Photograph taken in SE comer of 48-acre field looking to the North and West.

16. Fallowing Program Field No. 63903-014. PVID Parcel No. 013001. Reclamation Field No. 6502. Canal & Gate No. D23-l-21N. Acres: 50. Start Date: October l, 2017.

Field Condition: Fallow; bare soil.

Photo No. 16.

Comment: Photo taken in extreme SE comer of50-acre triangular shaped field looking straight West.

17. Fallowing Program Field No. 63899-004 PVID Parcel No. 01500 I. Reclamation Field No. 5770. Canal & Gate No. Cl22W. Acres: I. Start Date: February 12, 2019.

Field Condition: Fallow; bare soil.

Photo No. 17.

Comment: Looking straight West at a I -acre strip along the South end of a cotton field. The remainder of the field is still in cotton stubble. The fallow portion has been disked.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program December 2019 Verification Report 7 18. Fallowing Program Field No. 63899-003. PVID Parcel No. 02l003. Reclamation Field No. 5492. Canal & Gate No. CI8-18N.

------• Acres: 19. Start Date: March l, 2018. Field Condition: Fallow; bare soil.

Comment: Photo taken in Northeast comer of field looking to the Southwest.

19. Fallowing Program Field No. 63899-003. 20. PVID Parcel No. 02l003. 21. Reclamation Field Nos. 5683. Canal & Gate No. CI8-18N. Photo No. 19 here is used for Inspection Parcels 19, 20 and 21. Comment: This field has multiple fallow contracts on it. The 19-acre fallowed segment is the south strip of the field. The photo was taken at the west edge of the field looking east. Inspection Parcel 19. Acres: 9. Start Date: March l, 2018. Field Condition: Fallow; bare soil.

Inspection Parcel No. 20. Acres: 5. Start Date: March l, 2018. Field Condition: Fallow, bare soil, recently disked. Comment: Bare, disked soil. The 5-acre fallow strip is in the North half of the field.

Inspection Parcel No. 21. Acres: 2. Start Date: March l, 2018. Field Condition: Fallow; bare soil. Comment: Bare, disked soil. The 2-acre fallow strip is the extreme north section of the field, a strip running from west to east.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program December 2019 Verification Report 8 22. Fallowing Program Field No. 63900-026. PVID Parcel No. 25005. Reclamation Field No. 5318. Canal & Gate No. D23- l-33E. Acres: 5. Start Date: August I, 2015.

Field Condition: Fallow; bare soil.

Photo No. 22.

Comment: Photo in NW comer looking East and South.

23. Fallowing Program Field No. 63900-032. PVID Parcel No. 026013. Reclamation Field No. 5319. Canal & Gate Nos. D23-l-32W. Acres: 35. Start Date: August I, 2015.

Field Condition: Fallow, bare soil.

Photo No. 23.

Comment: Photo in Northeast comer looking West and South. Bare, ridged soil.

24. Fallowing Program Field No. 63900-011. PVID Parcel No. 035006. Reclamation Field No. 4346. Canal & Gate No. CI 8-l 8N. Acres: 17. Start Date: August I, 2016.

Field Condition: Fallow; bare soil.

Photo No. 24.

Comment: Photo taken in NW comer of field looking to the South and to the East.

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program December 2019 Verification Report 9

25 . Fallowing Program Field No. 63900-019 PVID Parcel No. 036003. Reclamation Field No.4138. Canal & Gate No. D23- l-46E. Acres: 23. Start Date: August l, 2016.

Field Condition: Fallow; bare soil

Photo No. 25.

Comment: Photo taken in the SW corner of the field looking to the NE.

Total acres inspected and verified as fallow during this field verification inspection visit: 543 acres within 25 parcels.

Based on the observations made and the information collected during the field verification inspection, the implementation of the extraordinary conservation measures noted above is: 181Confirmed • Unconfirmed

~~ ,.CV~ January-ZJ'. 2020 Troyirth, Inspector Date

Januar:#8, 2020 Date

Metropolitan Funded Palo Verde Irrigation District Forbearance and Fallowing Program December 2019 Verification Report United States Department of the Interior

BUREAU OF RECLAMATION P.O. Box 6 1470 Boul der City, NY 89006-1 470

11' REPLY REFER TO· May 15 2020 LC-4220 2.2.4.23

CERTIFI ED- RETURN RECEIPT REQUESTED

Mr. Wil liam Hasencamp Manager, Colorado River Resources The Metropolitan Water District of Southern California P.O. Box 54153 Los Angeles, CA 90054-0153

Subject: Verification of Extraordinary Conservation (EC) Intentionally Created Surplus (ICS) Created by The Metropolitan Water District of Southern California (MWD) in Calendar Year (CY) 2018

Dear Mr. Hasencamp:

The Bureau of Reclamation has received MWD's Metropolitan Intentionally Created Surplus Certification Report for Palo Verde Irrigation District Forbearance and Fallowing Program and Imperial Irrigation District Water Conservation Program Calendar Year 2018 (Certification Report). M WD's Certification Report was submitted in fulfillment of the requirements set forth in Section XI.G .3.D of the 2007 Record of Decision for Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations for Lake Powell and Lake Mead (2007 Interim Guidelines) regarding the accounting for ICS. In accordance with Section X I.G.3.D.2 of the 2007 Interim Guidelines, this letter provides MWD with notice of my determination regarding the amount of ICS created by MWD in CY 2018.

MWD's Certification Report documents that MWD created a total of 130,946 acre-feet (AF) of EC ICS in CY 20 18 from the foll owing two conservation activities: ( I) 95,752 AF from the Metropolitan Funded Palo Verde Irrigation District Forbearance and Fall owing Program; and (2) 35,194 AF from the Metropolitan Funded Imperial Irrigation District Water Conservation Program.

Reclamation has reviewed the information contained in MWD's Cettification Report and confirms it adequately demonstrates the amount of ICS created and that the methods of creation were consistent with MWD's approved ICS Plan of Creation/ Exhibits G and Hof the Lower Colorado River Basin Intentionally Created Surplus Forbearance Agreement, and the Delive,y Agreement (Contract No. 07-XX- 30-W05 I 9) between the United States and M WO. Therefore, I verify and make the final determination that M WD created 130,946 AF of EC ICS in CY 2018, prior to accounting for the one-time deduction of 5 percent for the benefit of additional system storage, as specified in Section XI.G.3.B.2 of the 2007 Interim Guideli nes. As noted in your November 8th letter, the total assessed losses on this ICS creation will be trued

1 Reclamation approved MWD's Modified Plan/or the Creation of£--.:1raord ina1y Conservation fnlenlionally Creal ed Surplus During Calendar Year 2018 by letter dated December 27, 2017. l NTERIOR REGION 8 • LOWER COLORADO BASIN ARIZONA. CALI FO RNIA*, NEVADA* • PARTIAL 2 up to 10 percent, as specified in Section IV.A. I of Lower Basin Drought Contingency Operations. This assessment will be reflected in the CY 2019 Colorado River Accounting and Water Use Report: Arizona, California and Nevada.

Thank you for submitting MWD's Certification Report. If you have questions, please contact Mr. Jeremy Dodds, Water Accounting and Verification Group Manager, at (702) 293-8164 or jdodds@ usbr.gov.

Sincerely,

Terrance J. Fulp, Ph.D. Regional Director Interior Region 8: Lower Colorado Basin Bureau of Reclamation cc: Mr. Christopher S. Harris Mr. Eric P. Witkoski Executive Director Executive Director Colorado Ri ver Board of California Colorado River Commission of Nevada 770 Fairmont A venue, Suite I 00 555 East Washington A venue, Suite 3 100 Glendale, CA 9 1203 Las Vegas, NV 8910 I

Mr. Thomas Buschatzke Mr. John Entsminger Director General Manager Ari zona Department of Water Resources Southern Nevada Water Authori ty P.O. Box 36020 I 00 I South Valley View Boulevard, MS 480 Phoenix, AZ 85067-6020 Las Vegas, NV 89 153

Mr. Charles B. Sherrill, Jr. Mr. Elston K. Grubaugh Chairman Manager/Secretary Mohave Valley Irrigation Well ton-Mohawk Irrigation and Drainage District and Drainage District 1460 East Commercial Street 30570 Wellton-Mohawk Drive Mohave Valley, AZ 86440 Well ton, AZ 85356

Mr. Theodore C. Cooke Tina Anderholt Shields, P. E. General Manager Water Department Manager Central Arizona Water Conservation District Imperi al Irrigation District P.O. Box 43020 P.O. Box 937 Phoenix, AZ 85080-3020 Imperial, CA 92251-0937

Honorable Dennis Patch Honorable Stephen R. Lewis Tribal Chairman Governor Colorado River Indian Tri bes Gila River Indian Community 26600 Mohave Road P.O. Box 97 Parker, AZ 85344 Sacaton, AZ 85 147-0097