Comments on CWC Draft WSIP Quantification Regulations Mar 14, 2016 Comment Letters Agency: California Water Commission Subject: Association of California Water Agencies’ Comments regarding California Water Commission Draft Water Storage Investment Program Quantification Regulations dated January 11, 2016 Letter excerpt: In order to ensure that project proponents can maximize the return on the Commission’s investment in the public benefits of storage projects, the Regulations should ensure that the Commission’s maintains the maximum allowable flexibility over the types of project costs that are fundable, and over the timing with which WSIP funds are made available to project developers. (a) The definition of “Capital Costs” in section 6000(a)(14) of the draft Regulations should include financing costs. In order to ensure that the full capital costs of a project are accurately presented and considered by the Commission, the definition of “capital costs” in section 6000(a)(14) of the draft Regulations should be clarified to expressly include the financing costs of a project. Financing costs can represent a significant portion of the costs associated with construction of infrastructure projects of any size and should be included in the Commission’s consideration of the costs of building a given project. To address this issue, we encourage the Commission to incorporate the language of the suggested amendment below. Suggested Amendment #6 Revise section 6000(a)(14)(C) to read as follows: “Costs incidentally but directly related to construction or acquisition, including, but not limited to, planning, engineering, construction management, architectural, and other design work, environmental impact reports and assessments, required environmental mitigation or compliance obligation expenses, appraisals, legal expenses, financing costs, site acquisitions, and necessary easements. Download ACWA’s comment letter
