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

Suggested Resources

3 RESOURCES
Comment Letter: US EPA and USACE Updated Definition of “Waters of the United States”

Agency: United States Environmental Protection Agency, United States Department of the Army Subject: U.S. Environmental Protection Agency and U.S. Army Corps of […]

Comment Letter: USDA Roadless Area Conservation Rule

Agency: United States Department of Agriculture Forest Service Subject: U.S. Department of Agriculture: Special Areas; Roadless Area Conservation — Docket ID […]

Comment Letter: Review of State Plans and Policies

Agency: State Water Resources Control Board Subject: Review of State Plans and Policies Letter excerpt:  The Association of California Water […]