Comments on Initial CWC Staff Evaluation of WSIP Projects’ Public Benefit Ratios

  • Jan 26, 2018
  • Comment Letters

Agency: California Water Commission

Subject: Storage: Concerns with Initial Evaluation of Project Public Benefit Ratios and the Need for Effective Communications Going Forward

Letter excerpt:

ACWA deeply appreciates the commitment by CWC Commissioners and staff who have worked diligently to move the program forward since the voters approved Proposition 1 in 2014. As explained below, however, ACWA now has significant concerns with the latest development regarding the public benefit ratios and the approach that staff has suggested going forward relative to communication between the applicants and CWC staff.

During the January 16, 2018 stakeholder briefing, the CWC staff informed participants that all of the project applicants failed to provide adequate technical and supporting documentation relative to public benefits, so the resulting adjusted project public benefit ratios (before the submittal of revised and/or additional information during the appeals process) were such that not one project could receive funding. (Staff adjusted all of the project PBRs to less than one, but the public benefit ratio cannot be less than one for a project to receive funding under the WSIP.) This initial result demonstrates a complete disconnect between all of the project applicants as to their understanding of what is required in the applications and the expectations of state reviewers. This disconnect is deeply concerning. The initial result clearly indicates that significant improvements in communications between CWC staff and the applicants is essential during the upcoming appeals process. Yet staff has informed the stakeholders and applicants that staff does not currently intend to allow for any further questions, clarifications or other communications during this appeals process.

ACWA requests that the Commissioners direct staff to use a more interactive and less oppositional process, which provides opportunities for applicant dialogue with staff reviewers and interaction between applicant technical staff and reviewer technical staff.

Download ACWA’s comment letter

Download CWC’s response to ACWA’s comment letter 

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