Water for America

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The Western Coalition of Arid States (WESTCAS) is an association of water professionals from water, wastewater, and irrigation agencies representing the states of Arizona, California, Colorado, Idaho, Nevada, New Mexico and Texas. WESTCAS recognizes that the arid west has a unique ecosystem. Many months have little or no rain and annual precipitation is often less the 12 inches. Consequently, it is essential to protect both the quantity and quality of our precious water supplies. To this end WESTCAS is dedicated to encouraging the development of water programs and regulations which assure adequate supplies of high quality water for those living in the arid regions while protecting the environment. We welcome this opportunity as a Stakeholder to comment on the Water for America Initiative (Initiative), per your Federal Register notice. WESTCAS recognizes that the United States Bureau of Reclamation (Bureau) is the premiere water resource organization in the Federal sector, and further supports it's Mission to water supply, resource development and protection of the environment. For many years the Bureau was a leader in bringing supplemental water to the parched landscape of the seventeen (17) western states, through its construction programs, and partnerships with member agencies in those states. It appears that the Bureau is embarking on a new course for the 21st Century, as outlined in your Water for America Initiative. The FY 2009, President's budget request is $31.9 million for the Bureau's activities under the Initiative. In reviewing the details of the Initiative, WESTCAS finds that the Bureau will devote most of this request for the continued funding of their current Challenge Grant Program under Water 2025, ($11 million), with another large allocation of $8.9 million for acceleration of critical ESA compliance activities. The remainder of the request will be used for Water Conservation Field Services Program and Basin Studies Program. WESTCAS recognizes that these efforts are important; however, considering that the backlog for authorized Title XVI projects alone is hundreds of millions of dollars, we are concerned that continued studies and small grants cannot build the infrastructure essential to managing our dwindling water resources. The Budget Request of $31.9 million would be better directed if it were applied to existing programs like: PL 102-575, Title XVI or PL-966 the old R&B funding program and PL984, the Small Reclamation Projects Act. These programs were the heart and soul of the Bureau in the past, and they actually built projects. Applying these funds to projects that have already been authorized, and that can have an almost immediate impact on the Arid West would, we believe, be a much better use of scarce Federal dollars and could have the greatest impact. Although WESTCAS appreciates the foundational need for water resource studies, we feel that the same State and local partners that would cost share in those studies on a 50/50 basis currently have much of the information the Bureau intends to collect. With a growing population, prolonged drought, and the impacts of climate change all impacting our water resources, we believe it is crucial that the Bureau not re-invent the wheel with regard to studies, when its resources can be better allocated to "shovels in the ground". We urge the Bureau to contact local and State agencies and ask them to share the information they already have, and for a fraction of the cost. For example, the State of Texas has engaged in a state-wide water resources study for almost a decade. This effort has been conducted in close cooperation with state agencies and the State Legislature, and has acquired a vast repository of information concerning 21st century water needs, which could be shared with the Bureau and other stakeholders. The Bureau should not recreate work that most States already completed or currently have in process concerning their future water resource needs. In addition to redirecting the study funds, WESTCAS urges the Bureau to add meaningful funding for water resource development to this initiative. A grant with a $300,000 cap is helpful. But, the backlog of water resource needs in the West is in amounts of billions of dollars. Cost-shared studies with a $300 K cap are unlikely to have an appreciable and timely impact on building the infrastructure needed within most states in the West. Although the Initiative overview describes three strategies, the Initiative only describes two of the strategies. The third strategy "Enhance Our Nation's Water Knowledge" that will be implemented by the USGS is not described in the Bureau's Initiative. WESTCAS would like to know whether the USGS has their own Implementation Plan, and suggests that since the Bureau is the lead agency, it would be helpful to comprehensively address all three strategies in this proposed Implementation Plan in a detailed manner. Advocacy groups like WESTCAS are particularly interested in your plans to coordinate with the USGS, because many of our member agencies have developed close daily working relationships with this agency over the decades. We urge you to address both how the Bureau of Reclamation plans to coordinate and take advantage of the knowledge that our member agencies have already developed with the USGS. The current Implementation Plan seems incomplete, and the reader is only provided two sentences with respect to the third USGS strategy on page 1 that read: …"Reclamation is coordinating closely with the USGS on implementing the Initiative. Wherever possible, Reclamation will incorporate data made available by USGS through the Initiative into Reclamation's efforts." In summary, the Initiative lays out a proposed implementation plan for distributing small amounts of funding across the 17 western states. Mathematically speaking, less than $2 million per western state would be distributed, if it were distributed equally. But the current distribution of funding ranges widely with some larger States within the service area of the Bureau receiving less than 1% of your annual budget, while other States receive varying amounts. Because of the likely State-by-State variation in funding, we question whether your proposed allocation of funding would have a true regional impact on the water needs of the Arid West. There is no doubt that there are willing local and State partners and other stakeholders that would enjoy the leverage of cost sharing on a 50/50 basis, even considering the small funding amounts available. However, one has to question the individual value of each study or grant-funded water resource project that would be prospectively accomplished, versus the value of contributing the $31.9 million funding instead to the completion of already authorized water resource project(s). Our WESTCAS review of the proposed Initiative finds that the Initiative appears to represent nothing more than a descriptive methodology for distributing small amounts of federal funding across the 17 western states. The Initiative lacks substance, and falls short of the following language contained in the document's conclusion on page 16. That language states: "Through the strategies and the programs described here, the Water for America Initiative will provide the vision and leadership necessary to help ensure sustainable water supplies in the West for the 21st century." With billions of dollars needed in the immediate future to meet the water needs of the Arid West, we do not see how this Initiative, as currently proposed, will allow the Bureau of Reclamation to be an effective Federal partner and provide the necessary leveraging of local and State dollars. WESTCAS does not readily see the products of "vision and leadership" emanating from the implementation of this Initiative. It is our suggestion that the conclusion is in need of re-wording. Thank you for the opportunity to provide comments on the Water fbr America Initiative. Sincerely, Charlie Nylander, President WESTCAS	09/16/2008

Comment

Submit Date

The Western Coalition of Arid States (WESTCAS) is an association of water professionals from water, wastewater, and irrigation agencies representing the states of Arizona, California, Colorado, Idaho, Nevada, New Mexico and Texas. WESTCAS recognizes that the arid west has a unique ecosystem. Many months have little or no rain and annual precipitation is often less the 12 inches. Consequently, it is essential to protect both the quantity and quality of our precious water supplies. To this end WESTCAS is dedicated to encouraging the development of water programs and regulations which assure adequate supplies of high quality water for those living in the arid regions while protecting the environment. We welcome this opportunity as a Stakeholder to comment on the Water for America Initiative (Initiative), per your Federal Register notice.

WESTCAS recognizes that the United States Bureau of Reclamation (Bureau) is the premiere water resource organization in the Federal sector, and further supports it's Mission to water supply, resource development and protection of the environment. For many years the Bureau was a leader in bringing supplemental water to the parched landscape of the seventeen (17) western states, through its construction programs, and partnerships with member agencies in those states. It appears that the Bureau is embarking on a new course for the 21st Century, as outlined in your Water for America Initiative.

The FY 2009, President's budget request is $31.9 million for the Bureau's activities under the Initiative. In reviewing the details of the Initiative, WESTCAS finds that the Bureau will devote most of this request for the continued funding of their current Challenge Grant Program under Water 2025, ($11 million), with another large allocation of $8.9 million for acceleration of critical ESA compliance activities. The remainder of the request will be used for Water Conservation Field Services Program and Basin Studies Program.

WESTCAS recognizes that these efforts are important; however, considering that the backlog for authorized Title XVI projects alone is hundreds of millions of dollars, we are concerned that continued studies and small grants cannot build the infrastructure essential to managing our dwindling water resources. The Budget Request of $31.9 million would be better directed if it were applied to existing programs like: PL 102-575, Title XVI or PL-966 the old R&B funding program and PL984, the Small Reclamation Projects Act. These programs were the heart and soul of the Bureau in the past, and they actually built projects. Applying these funds to projects that have already been authorized, and that can have an almost immediate impact on the Arid West would, we believe, be a much better use of scarce Federal dollars and could have the greatest impact.

Although WESTCAS appreciates the foundational need for water resource studies, we feel that the same State and local partners that would cost share in those studies on a 50/50 basis currently have much of the information the Bureau intends to collect. With a growing population, prolonged drought, and the impacts of climate change all impacting our water resources, we believe it is crucial that the Bureau not re-invent the wheel with regard to studies, when its resources can be better allocated to "shovels in the ground".

We urge the Bureau to contact local and State agencies and ask them to share the information they already have, and for a fraction of the cost. For example, the State of Texas has engaged in a state-wide water resources study for almost a decade. This effort has been conducted in close cooperation with state agencies and the State Legislature, and has acquired a vast repository of information concerning 21st century water needs, which could be shared with the Bureau and other stakeholders. The Bureau should not recreate work that most States already completed or currently have in process concerning their future water resource needs.

In addition to redirecting the study funds, WESTCAS urges the Bureau to add meaningful funding for water resource development to this initiative. A grant with a $300,000 cap is helpful. But, the backlog of water resource needs in the West is in amounts of billions of dollars. Cost-shared studies with a $300 K cap are unlikely to have an appreciable and timely impact on building the infrastructure needed within most states in the West.

Although the Initiative overview describes three strategies, the Initiative only describes two of the strategies. The third strategy "Enhance Our Nation's Water Knowledge" that will be implemented by the USGS is not described in the Bureau's Initiative. WESTCAS would like to know whether the USGS has their own Implementation Plan, and suggests that since the Bureau is the lead agency, it would be helpful to comprehensively address all three strategies in this proposed Implementation Plan in a detailed manner. Advocacy groups like WESTCAS are particularly interested in your plans to coordinate with the USGS, because many of our member agencies have developed close daily working relationships with this agency over the decades. We urge you to address both how the Bureau of Reclamation plans to coordinate and take advantage of the knowledge that our member agencies have already developed with the USGS.

The current Implementation Plan seems incomplete, and the reader is only provided two sentences with respect to the third USGS strategy on page 1 that read:

…"Reclamation is coordinating closely with the USGS on implementing the Initiative. Wherever possible, Reclamation will incorporate data made available by USGS through the Initiative into Reclamation's efforts."

In summary, the Initiative lays out a proposed implementation plan for distributing small amounts of funding across the 17 western states. Mathematically speaking, less than $2 million per western state would be distributed, if it were distributed equally. But the current distribution of funding ranges widely with some larger States within the service area of the Bureau receiving less than 1% of your annual budget, while other States receive varying amounts. Because of the likely State-by-State variation in funding, we question whether your proposed allocation of funding would have a true regional impact on the water needs of the Arid West. There is no doubt that there are willing local and State partners and other stakeholders that would enjoy the leverage of cost sharing on a 50/50 basis, even considering the small funding amounts available. However, one has to question the individual value of each study or grant-funded water resource project that would be prospectively accomplished, versus the value of contributing the $31.9 million funding instead to the completion of already authorized water resource project(s).

Our WESTCAS review of the proposed Initiative finds that the Initiative appears to represent nothing more than a descriptive methodology for distributing small amounts of federal funding across the 17 western states. The Initiative lacks substance, and falls short of the following language contained in the document's conclusion on page 16.

That language states: "Through the strategies and the programs described here, the Water for America Initiative will provide the vision and leadership necessary to help ensure sustainable water supplies in the West for the 21st century." With billions of dollars needed in the immediate future to meet the water needs of the Arid West, we do not see how this Initiative, as currently proposed, will allow the Bureau of Reclamation to be an effective Federal partner and provide the necessary leveraging of local and State dollars.

WESTCAS does not readily see the products of "vision and leadership" emanating from the implementation of this Initiative. It is our suggestion that the conclusion is in need of re-wording.

Thank you for the opportunity to provide comments on the Water fbr America Initiative.

Sincerely,
Charlie Nylander, President
WESTCAS

09/16/2008