STATE WATER RESOURCES CONTROL BOARD PUBLIC HEARING 1998 BAY-DELTA WATER RIGHTS HEARING HELD AT: BONDERSON BUILDING 901 P STREET SACRAMENTO, CALIFORNIA THURSDAY, FEBRUARY 25, 1999 9:00 A.M. Reported by: ESTHER F. WIATRE CSR NO. 1564 CAPITOL REPORTERS (916) 923-5447 1 APPEARANCES BOARD MEMBERS: 2 JAMES STUBCHAER, COHEARING OFFICER 3 JOHN W. BROWN, COHEARING OFFICER MARY JANE FORSTER 4 MARC DEL PIERO 5 STAFF MEMBERS: 6 WALTER PETTIT, EXECUTIVE DIRECTOR VICTORIA WHITNEY, CHIEF BAY-DELTA UNIT 7 THOMAS HOWARD, SUPERVISING ENGINEER 8 COUNSEL: 9 WILLIAM R. ATTWATER, CHIEF COUNSEL BARBARA LEIDIGH 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 PRINCETON CODORA GLENN IRRIGATION DISTRICT, et al.: 3 FROST, DRUP & ATLAS 134 West Sycamore Street 4 Willows, California 95988 BY: J. MARK ATLAS, ESQ. 5 JOINT WATER DISTRICTS: 6 MINASIAN, SPRUANCE, BABER, MEITH, SOARES & SEXTON: 7 P.O. BOX 1679 Oroville, California 95965 8 BY: WILLIAM H. BABER III, ESQ. 9 CALIFORNIA SPORTFISHING PROTECTION ALLIANCE: 10 ROBERT J. BAIOCCHI P.O. Box 357 11 Quincy, California 12 BELLA VISTA WATER DISTRICT: 13 BRUCE L. BELTON, ESQ. 2525 Park Marina Drive, Suite 102 14 Redding, California 96001 15 WESTLANDS WATER DISTRICT: 16 KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD 400 Capitol Mall, 27th Floor 17 Sacramento, California 95814 BY: THOMAS W. BIRMINGHAM, ESQ. 18 and AMELIA MINABERRIGARAI, ESQ. 19 THE BAY INSTITUTE OF SAN FRANCISCO: 20 GARY BOBKER 21 55 Shaver Street, Suite 330 San Rafael, California 94901 22 CITY OF ANTIOCH, et al.: 23 FREDERICK BOLD, JR., ESQ. 24 1201 California Street, Suite 1303 San Francisco, California 94109 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 LEAGUE OF WOMEN VOTERS: 3 ROBERTA BORGONOVO 2480 Union Street 4 San Francisco, California 94123 5 UNITED STATES DEPARTMENT OF THE INTERIOR: 6 OFFICE OF THE SOLICITOR 2800 Cottage Way, Room E1712 7 Sacramento, California 95825 BY: ALF W. BRANDT, ESQ. 8 CALIFORNIA URBAN WATER AGENCIES: 9 BYRON M. BUCK 10 455 Capitol Mall, Suite 705 Sacramento, California 95814 11 RANCHO MURIETA COMMUNITY SERVICES DISTRICT: 12 MCDONOUGH, HOLLAND & ALLEN 13 555 Capitol Mall, 9th Floor Sacramento, California 95814 14 BY: VIRGINIA A. CAHILL, ESQ. 15 CALIFORNIA DEPARTMENT OF FISH AND GAME: 16 OFFICE OF ATTORNEY GENERAL 1300 I Street, Suite 1101 17 Sacramento, California 95814 BY: MATTHEW CAMPBELL, ESQ. 18 NATURAL RESOURCES DEFENSE COUNCIL: 19 HAMILTON CANDEE, ESQ. 20 71 Stevenson Street San Francisco, California 94105 21 ARVIN-EDISON WATER STORAGE DISTRICT, et al.: 22 DOOLEY HERR & WILLIAMS 23 3500 West Mineral King Avenue, Suite C Visalia, California 93291 24 BY: DANIEL M. DOOLEY, ESQ. 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 SACRAMENTO MUNICIPAL UTILITY DISTRICT: 3 LESLIE A. DUNSWORTH, ESQ. 6201 S Street 4 Sacramento, California 95817 5 SOUTH SAN JOAQUIN IRRIGATION DISTRICT, et al.: 6 BRAY, GEIGER, RUDQUIST & NUSS 311 East Main Street, 4th Floor 7 Stockton, California 95202 BY: STEVEN P. EMRICK, ESQ. 8 EAST BAY MUNICIPAL UTILITY DISTRICT: 9 EBMUD OFFICE OF GENERAL COUNSEL 10 375 Eleventh Street Oakland, California 94623 11 BY: FRED S. ETHERIDGE, ESQ. 12 GOLDEN GATE AUDUBON SOCIETY: 13 ARTHUR FEINSTEIN 2530 San Pablo Avenue, Suite G 14 Berkeley, California 94702 15 CONAWAY CONSERVANCY GROUP: 16 UREMOVIC & FELGER P.O. Box 5654 17 Fresno, California 93755 BY: WARREN P. FELGER, ESQ. 18 THOMES CREEK WATER ASSOCIATION: 19 THOMES CREEK WATERSHED ASSOCIATION 20 P.O. Box 2365 Flournoy, California 96029 21 BY: LOIS FLYNNE 22 COURT APPOINTED REPS OF WESTLANDS WD AREA 1, et al.: 23 LAW OFFICES OF SMILAND & KHACHIGIAN 601 West Fifth Street, Seventh Floor 24 Los Angeles, California 90075 BY: CHRISTOPHER G. FOSTER, ESQ. 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 CITY AND COUNTY OF SAN FRANCISCO: 3 OFFICE OF THE CITY ATTORNEY 1390 Market Street, Sixth Floor 4 San Francisco, California 94102 BY: DONN W. FURMAN, ESQ. 5 CAMP FAR WEST IRRIGATION DISTRICT, et al.: 6 DANIEL F. GALLERY, ESQ. 7 926 J Street, Suite 505 Sacramento, California 95814 8 BOSTON RANCH COMPANY, et al.: 9 J.B. BOSWELL COMPANY 10 101 West Walnut Street Pasadena, California 91103 11 BY: EDWARD G. GIERMANN 12 SAN JOAQUIN RIVER GROUP AUTHORITY, et al.: 13 GRIFFTH, MASUDA & GODWIN 517 East Olive Street 14 Turlock, California 95381 BY: ARTHUR F. GODWIN, ESQ. 15 NORTHERN CALIFORNIA WATER ASSOCIATION: 16 RICHARD GOLB 17 455 Capitol Mall, Suite 335 Sacramento, California 95814 18 PLACER COUNTY WATER AGENCY, et al.: 19 KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD 20 400 Capitol Mall, 27th Floor Sacramento, California 95814 21 BY: JANET GOLDSMITH, ESQ. 22 ENVIRONMENTAL DEFENSE FUND: 23 DANIEL SUYEYASU, ESQ. and 24 THOMAS J. GRAFF, ESQ. 5655 College Avenue, Suite 304 25 Oakland, California 94618 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 CALAVERAS COUNTY WATER DISTRICT: 3 SIMON GRANVILLE P.O. Box 846 4 San Andreas, California 95249 5 CHOWCHILLA WATER DISTRICT, et al.: 6 GREEN, GREEN & RIGBY P.O. Box 1019 7 Madera, California 93639 BY: DENSLOW GREEN, ESQ. 8 CALIFORNIA FARM BUREAU FEDERATION: 9 DAVID J. GUY, ESQ. 10 2300 River Plaza Drive Sacramento, California 95833 11 SANTA CLARA VALLEY WATER DISTRICT: 12 MORRISON & FORESTER 13 755 Page Mill Road Palo Alto, California 94303 14 BY: KEVIN T. HAROFF, ESQ. 15 CITY OF SHASTA LAKE: 16 ALAN N. HARVEY P.O. Box 777 17 Shasta Lake, California 96019 18 COUNTY OF STANISLAUS: 19 MICHAEL G. HEATON, ESQ. 926 J Street 20 Sacramento, California 95814 21 GORRILL LAND COMPANY: 22 GORRILL LAND COMPANY P.O. Box 427 23 Durham, California 95938 BY: DON HEFFREN 24 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 SOUTH DELTA WATER AGENCY: 3 JOHN HERRICK, ESQ. 3031 West March Lane, Suite 332 East 4 Stockton, California 95267 5 COUNTY OF GLENN: 6 NORMAN Y. HERRING 525 West Sycamore Street 7 Willows, California 95988 8 REGIONAL COUNCIL OF RURAL COUNTIES: 9 MICHAEL B. JACKSON, ESQ. 1020 Twelfth Street, Suite 400 10 Sacramento, California 95814 11 DEER CREEK WATERSHED CONSERVANCY: 12 JULIE KELLY P.O. Box 307 13 Vina, California 96092 14 DELTA TRIBUTARY AGENCIES COMMITTEE: 15 MODESTO IRRIGATION DISTRICT P.O. Box 4060 16 Modesto, California 95352 BY: BILL KETSCHER 17 SAVE THE SAN FRANCISCO BAY ASSOCIATION: 18 SAVE THE BAY 19 1736 Franklin Street Oakland, California 94612 20 BY: CYNTHIA L. KOEHLER, ESQ. 21 BATTLE CREEK WATERSHED LANDOWNERS: 22 BATTLE CREEK WATERSHED CONSERVANCY P.O. Box 606 23 Manton, California 96059 24 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 BUTTE SINK WATERFOWL ASSOCIATION, et al.: 3 MARTHA H. LENNIHAN, ESQ. 455 Capitol Mall, Suite 300 4 Sacramento, California 95814 5 CITY OF YUBA CITY: 6 WILLIAM P. LEWIS 1201 Civic Center Drive 7 Yuba City 95993 8 BROWNS VALLEY IRRIGATION DISTRICT, et al.: 9 BARTKEWICZ, KRONICK & SHANAHAN 1011 22nd Street, Suite 100 10 Sacramento, California 95816 BY: ALAN B. LILLY, ESQ. 11 CONTRA COSTA WATER DISTRICT: 12 BOLD, POLISNER, MADDOW, NELSON & JUDSON 13 500 Ygnacio Valley Road, Suite 325 Walnut Creek, California 94596 14 BY: ROBERT B. MADDOW, ESQ. 15 GRASSLAND WATER DISTRICT: 16 DON MARCIOCHI 22759 South Mercey Springs Road 17 Los Banos, California 93635 18 SAN LUIS CANAL COMPANY: 19 FLANNIGAN, MASON, ROBBINS & GNASS 3351 North M Street, Suite 100 20 Merced, California 95344 BY: MICHAEL L. MASON, ESQ. 21 STONY CREEK BUSINESS AND LAND OWNERS COALITION: 22 R.W. MCCOMAS 23 4150 County Road K Orland, California 95963 24 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 TRI-DAM POWER AUTHORITY: 3 TUOLUMNE UTILITIES DISTRICT P.O. Box 3728 4 Sonora, California 95730 BY: TIM MCCULLOUGH 5 DELANO-EARLIMART IRRIGATION DISTRICT, et al.: 6 MINASIAN, SPRUANCE, BABER, MEITH, SOARES & SEXTON 7 P.O. Box 1679 Oroville, California 95965 8 BY: JEFFREY A. MEITH, ESQ. 9 HUMANE FARMING ASSOCIATION: 10 BRADLEY S. MILLER 1550 California Street, Suite 6 11 San Francisco, California 94109 12 CORDUA IRRIGATION DISTRICT, et al.: 13 MINASIAN, SPRUANCE, BABER, MEITH, SOARES & SEXTON P.O. Box 1679 14 Oroville, California 95965 BY: PAUL R. MINASIAN, ESQ. 15 EL DORADO COUNTY WATER AGENCY: 16 DE CUIR & SOMACH 17 400 Capitol Mall, Suite 1900 Sacramento, California 95814 18 BY: DONALD B. MOONEY, ESQ. 19 GLENN COUNTY FARM BUREAU: 20 STEVE MORA 501 Walker Street 21 Orland, California 95963 22 MODESTO IRRIGATION DISTRICT: 23 JOEL MOSKOWITZ P.O. Box 4060 24 Modesto, California 95352 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 PACIFIC GAS & ELECTRIC: 3 RICHARD H. MOSS, ESQ. P.O. Box 7442 4 San Francisco, California 94120 5 CENTRAL DELTA WATER AGENCY, et al.: 6 NOMELLINI, GRILLI & MCDANIEL P.O. Box 1461 7 Stockton, California 95201 BY: DANTE JOHN NOMELLINI, ESQ. 8 and DANTE JOHN NOMELLINI, JR., ESQ. 9 TULARE LAKE BASIN WATER STORAGE UNIT: 10 MICHAEL NORDSTROM 11 1100 Whitney Avenue Corcoran, California 93212 12 AKIN RANCH, et al.: 13 DOWNEY, BRAND, SEYMOUR & ROHWER 14 555 Capitol Mall, 10th Floor Sacramento, California 95814 15 BY: KEVIN M. O'BRIEN, ESQ. 16 OAKDALE IRRIGATION DISTRICT: 17 O'LAUGHLIN & PARIS 870 Manzanita Court, Suite B 18 Chico, California 95926 BY: TIM O'LAUGHLIN, ESQ. 19 SIERRA CLUB: 20 JENNA OLSEN 21 85 Second Street, 2nd Floor San Francisco, California 94105 22 YOLO COUNTY BOARD OF SUPERVISORS: 23 LYNNEL POLLOCK 24 625 Court Street Woodland, California 95695 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 PATRICK PORGANS AND ASSOCIATES: 3 PATRICK PORGANS P.O. Box 60940 4 Sacramento, California 95860 5 BROADVIEW WATER DISTRICT, et al.: 6 DIANE RATHMANN 7 FRIENDS OF THE RIVER: 8 BETSY REIFSNIDER 128 J Street, 2nd Floor 9 Sacramento, California 95814 10 MERCED IRRIGATION DISTRICT: 11 FLANAGAN, MASON, ROBBINS & GNASS P.O. Box 2067 12 Merced, California 95344 BY: KENNETH M. ROBBINS, ESQ. 13 CENTRAL SAN JOAQUIN WATER CONSERVATION DISTRICT: 14 REID W. ROBERTS, ESQ. 15 311 East Main Street, Suite 202 Stockton, California 95202 16 METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA: 17 JAMES F. ROBERTS 18 P.O. Box 54153 Los Angeles, California 90054 19 SACRAMENTO AREA WATER FORUM: 20 CITY OF SACRAMENTO 21 980 9th Street, 10th Floor Sacramento, California 95814 22 BY: JOSEPH ROBINSON, ESQ. 23 24 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 TUOLUMNE RIVER PRESERVATION TRUST: 3 NATURAL HERITAGE INSTITUTE 114 Sansome Street, Suite 1200 4 San Francisco, California 94194 BY: RICHARD ROOS-COLLINS, ESQ. 5 CALIFORNIA DEPARTMENT OF WATER RESOURCES: 6 DAVID SANDINO, ESQ. 7 CATHY CROTHERS, ESQ. P.O. Box 942836 8 Sacramento, California 94236 9 FRIANT WATER USERS AUTHORITY: 10 GARY W. SAWYERS, ESQ. 575 East Alluvial, Suite 101 11 Fresno, California 93720 12 KERN COUNTY WATER AGENCY: 13 KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD 400 Capitol Mall, 27th Floor 14 Sacramento, California 95814 BY: CLIFFORD W. SCHULZ, ESQ. 15 SAN JOAQUIN RIVER EXCHANGE CONTRACTORS: 16 MINASIAN, SPRUANCE, BABER, MEITH, SOARES & SEXTON: 17 P.O. Box 1679 Oroville, California 95965 18 BY: MICHAEL V. SEXTON, ESQ. 19 SAN JOAQUIN COUNTY: 20 NEUMILLER & BEARDSLEE P.O. Box 20 21 Stockton, California 95203 BY: THOMAS J. SHEPHARD, SR., ESQ. 22 CITY OF STOCKTON: 23 DE CUIR & SOMACH 24 400 Capitol Mall, Suite 1900 Sacramento, California 95814 25 BY: PAUL S. SIMMONS, ESQ. CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 ORLAND UNIT WATER USERS' ASSOCIATION: 3 MINASIAN, SPRUANCE, BABER, MEITH, SOARES & SEXTON P.O. Box 1679 4 Oroville, California 95965 BY: M. ANTHONY SOARES, ESQ. 5 GLENN-COLUSA IRRIGATION DISTRICT: 6 DE CUIR & SOMACH 7 400 Capitol Mall, Suite 1900 Sacramento, California 95814 8 BY: STUART L. SOMACH, ESQ. 9 NORTH SAN JOAQUIN WATER CONSERVATION DISTRICT: 10 JAMES F. SORENSEN CONSULTING CIVIL ENGINEER, INC. 209 South Locust Street 11 Visalia, California 93279 BY: JAMES F. SORENSEN 12 PARADISE IRRIGATION DISTRICT: 13 MINASIAN, SPRUANCE, BABER, MEITH, SOARES & SEXTON 14 P.O. Box 1679 Oroville, California 95695 15 BY: WILLIAM H. SPRUANCE, ESQ. 16 COUNTY OF COLUSA: 17 DONALD F. STANTON, ESQ. 1213 Market Street 18 Colusa, California 95932 19 COUNTY OF TRINITY: 20 COUNTY OF TRINITY - NATURAL RESOURCES P.O. Box 156 21 Hayfork, California 96041 BY: TOM STOKELY 22 CITY OF REDDING: 23 JEFFERY J. SWANSON, ESQ. 24 2515 Park Marina Drive, Suite 102 Redding, California 96001 25 CAPITOL REPORTERS (916) 923-5447 1 REPRESENTATIVES 2 TULARE IRRIGATION DISTRICT: 3 TEHAMA COUNTY RESOURCE CONSERVATION DISTRICT 2 Sutter Street, Suite D 4 Red Bluff, California 96080 BY: ERNEST E. WHITE 5 STATE WATER CONTRACTORS: 6 BEST BEST & KREIGER 7 P.O. Box 1028 Riverside, California 92502 8 BY: ERIC GARNER, ESQ. 9 COUNTY OF TEHAMA, et al.: 10 COUNTY OF TEHAMA BOARD OF SUPERVISORS: P.O. Box 250 11 Red Bluff, California 96080 BY: CHARLES H. WILLARD 12 MOUNTAIN COUNTIES WATER RESOURCES ASSOCIATION: 13 CHRISTOPHER D. WILLIAMS 14 P.O. Box 667 San Andreas, California 95249 15 JACKSON VALLEY IRRIGATION DISTRICT: 16 HENRY WILLY 17 6755 Lake Amador Drive Ione, California 95640 18 SOLANO COUNTY WATER AGENCY, et al.: 19 HERUM, CRABTREE, DYER, ZOLEZZI & TERPSTRA 20 2291 West March Lane, S.B.100 Stockton, California 95207 21 BY: JEANNE M. ZOLEZZI, ESQ. 22 ---oOo--- 23 24 25 CAPITOL REPORTERS (916) 923-5447 1 INDEX 2 PAGE 3 RESUMPTION OF HEARING: 10754 4 SAN JOAQUIN RIVER GROUP AUTHORITY: SUSHIL ARORA 5 DIRECT EXAMINATION: BY MR. GODWIN 10754 6 CROSS-EXAMINATION: BY MR. O'LAUGHLIN 10783 7 BY MR. JACKSON 10784 BY MR. BOARD MEMBERS 10791 8 REDIRECT-EXAMINATION: BY MR. GODWIN 10792 9 RECROSS-EXAMINATION: BY MR. O'LAUGHLIN 10794 10 BY MR. JACKSON 10795 BY BOARD MEMBERS 11 JO ANNE KIPPS 12 LESLIE GROBER DIRECT EXAMINATION: 13 BY MR. GODWIN 10798 CROSS-EXAMINATION: 14 BY MR. HERRICK 10832 BY MR. JACKSON 10844 15 BY MR. O'LAUGHLIN 10845 BY STAFF 10859 16 BY BOARD MEMBERS 10864 17 18 ---oOo--- 19 20 21 22 23 24 25 CAPITOL REPORTERS (916) 923-5447 1 SACRAMENTO, CALIFORNIA 2 FEBRUARY 25, 1999 3 ---oOo--- 4 C.O. STUBCHAER: Good morning. We will call the 5 hearing to order. 6 Mr. Godwin. 7 MR. GODWIN: Good morning, Mr. Chairman, Members of the 8 Board. My name is Arthur Godwin. I am appearing today for 9 the San Joaquin River Group Authority. I would like to call 10 my first witness, Mr. Sushil Arora of the Department of 11 Water Resources. 12 C.O. STUBCHAER: Mr. Godwin, are you going to have 13 individuals or as a panel or as presentation as individuals 14 and cross-examine them as a panel? 15 MR. GODWIN: I am doing Mr. Arora separately, and then 16 Ms. Kipps and Mr. Grober as a panel. And they will be 17 cross-examined today as a panel, but Mr. Arora will be 18 cross-examined separately. 19 C.O. STUBCHAER: Morning. Can you please -- you are 20 going to ask him to state his name for the record? 21 ---oOo--- 22 DIRECT-EXAMINATION OF 23 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 24 BY MR. GODWIN 25 MR. GODWIN: For the record, could you state your name, CAPITOL REPORTERS (916) 923-5447 10754 1 please. 2 MR. ARORA: Sushil Arora. Sushil, S-u-s-h-i-l; Arora, 3 A-r-o-r-a. 4 MR. GODWIN: Have you taken the oath, Mr. Arora? 5 MR. ARORA: Yes. I am part of the -- my resume or 6 whatever they call -- 7 MR. GODWIN: You will need to stand up. 8 (Oath administered by C.O. Stubchaer.) 9 MR. GODWIN: Further, in this phase of the hearing, 10 South Delta Water Agency represented numerous opinions and 11 thoughts about the development and results of the studies 12 that were performed to evaluate the recirculation proposal. 13 Upon review of that record I found it to be confusing and in 14 some cases it is in error, and I brought Mr. Arora in to 15 straighten out the record and correct some of those 16 inconsistencies. 17 Mr. Arora, did the Department of Water Resources, were 18 they asked to assist in evaluating the recirculation 19 proposal? 20 MR. ARORA: Yes, please. 21 MR. GODWIN: Who was it that asked DWR to assist in 22 this evaluation? 23 MR. ARORA: It was, I think, specifically Alex 24 Hildebrand. A group setting, a meeting, I was invited to 25 come over there, and Alex Hildebrand asked for a study from CAPITOL REPORTERS (916) 923-5447 10755 1 the Department. 2 MR. GODWIN: It was a group of people that included 3 Alex and others that were evaluating the recirculation? 4 MR. ARORA: Yes, that is right. 5 MR. GODWIN: What was the scope of the assistance that 6 DWR was asked to provide in this? 7 MR. ARORA: Essentially, we were asked to perform a 8 DWRSIM Model study to meet his needs. 9 MR. GODWIN: That DWRSIM study, then, was to provide 10 hydrologic data that was for the San Joaquin River that 11 would be incorporated into further studies? 12 MR. ARORA: Yes, please. 13 MR. GODWIN: Did you personally perform the study that 14 is identified as DWRSIM Study 468A? 15 MR. ARORA: This study was performed by my unit, my 16 group. I did not perform directly, but I supervised my 17 staff. I am responsible for their work. 18 MR. GODWIN: What type of hydrologic data was developed 19 for the San Joaquin River as a result of that study? 20 MR. ARORA: It's mainly information which comes 21 automatically from the model, but it is flows at different 22 locations, facilities; at San Joaquin station, at Vernalis, 23 which we modeled. And then other information on storages, 24 flows, stuff like that. 25 MR. GODWIN: So, it was a simulated operation of the CAPITOL REPORTERS (916) 923-5447 10756 1 San Joaquin River upstream of Vernalis? 2 MR. ARORA: Yes. 3 MR. GODWIN: That included the period of time from 1922 4 through 1994? 5 MR. ARORA: Yes, that's right. 6 MR. GODWIN: I want to explore some of the assumptions 7 that you used for the Vernalis flow and water quality 8 objectives. What did you assume for the water quality 9 objectives? 10 MR. ARORA: We were asked to assume what we have in 11 Water Quality Control Plan which is the salinity standard at 12 Vernalis. I believe it is .7 EC as part of the year and 1.0 13 EC part of the year. 14 MR. GODWIN: Those water quality objectives, then, were 15 those met through New Melones' operations? 16 MR. ARORA: That's right. 17 MR. GODWIN: What did you assume for the flow 18 objectives at Vernalis? 19 MR. ARORA: In this particular study we were asked not 20 to assume flow objectives and provide information. What we 21 come out as if we don't have flow objectives and then to do 22 something with that and compare against the requirements and 23 get some information as to how much deficit we are in if we 24 didn't meet flow objectives and how much water we need 25 additional to meet the standards at Vernalis, flow standard CAPITOL REPORTERS (916) 923-5447 10757 1 at Vernalis. 2 MR. GODWIN: So then, if I am correct then, the 3 underlying assumption of this study, 468A, was the 4 achievement of the water quality objectives at Vernalis 5 without consideration of meeting the 1995 Water Quality 6 Control Plan flow objectives at Vernalis? 7 MR. ARORA: That's right. 8 MR. GODWIN: The second area of assumptions involves 9 New Melones operation. What did you assume for New Melones' 10 operations? 11 MR. ARORA: Well, in the study we assumed that New 12 Melones was -- 13 THE REPORTER: I'm sorry, I didn't understand. 14 MR. ARORA: New Melones Reservoir is designed for -- in 15 this particular study assumed designed for meeting the 16 in-basin needs of the Stanislaus and any additional water 17 quality objectives we need to be met, water quality 18 standards. 19 MR. GODWIN: With regard to the those Stanislaus River 20 demands, could you briefly describe what those demands were 21 that were used in the model. 22 MR. ARORA: Do the best I can. In this study we 23 assumed that design operation going to be only meant for the 24 in-basin requirements, which is -- which means the Oakdale 25 demands, which is a water rights user along Stanislaus, CAPITOL REPORTERS (916) 923-5447 10758 1 which is about 600,000 acre-feet in a normal year. 2 We assumed CVP contract demand of a maximum 155,000 3 acre-feet in a given year. And then we had fish flow 4 objectives below Godwin Dam we assumed, and I think we also 5 assumed some of the DO, dissolved oxygen, requirement would 6 be met for New Melones, these four distinct demands on New 7 Melones. And in addition we had, like I mentioned earlier, 8 any additional objectives to be made for water quality 9 purpose at Vernalis. 10 C.O. BROWN: Mr. Chairman. 11 C.O. STUBCHAER: Mr. Brown. 12 C.O. BROWN: Clarification. The Oakdale 600,000, that 13 includes South San Joaquin? 14 MR. ARORA: Yes, yes. 15 MR. GODWIN: I was going to ask that. 16 The fish flows, those were based on the 1987 Department 17 of Fish and Game agreement? 18 MR. ARORA: That's right. 19 MR. GODWIN: So, then the DWRSIM Study 468A did not use 20 the Interim Operations Plan for the New Melones Reservoir; 21 is that right? 22 MR. ARORA: We did not use in the study. At that time 23 we did not have standard lined up, so we used what we had 24 given my staff, and essentially information from Bureau 25 staff in some meetings. CAPITOL REPORTERS (916) 923-5447 10759 1 MR. GODWIN: The third area of assumptions involves the 2 operation of the east side tributaries, the Tuolumne River 3 and the Merced River. What did you assume for those 4 tributaries? 5 MR. ARORA: In the study we assumed that they are only 6 meant for their local needs. That, therefore, we did not 7 impose any additional obligation to meet either flow or 8 salinity objectives at Vernalis. 9 MR. GODWIN: So, in summary, you simulated an operation 10 of the San Joaquin River that has the Merced and Tuolumne 11 Rivers operating as you understand they currently do to meet 12 their own tributary needs, New Melones operating for 13 Stanislaus River needs only, New Melones releasing whatever 14 water is necessary to meet the 1995 water quality objectives 15 at Vernalis, and the Vernalis flow objectives being ignored 16 and met only incidentally by these other operations and 17 naturally occurring hydrology? 18 MR. ARORA: Yes, yes. 19 MR. GODWIN: You provided some information to, I 20 believe, Mr. Grober and Ms. Kipps that was derived from the 21 DWRSIM Study 468A; is that correct? 22 MR. ARORA: That's right. 23 MR. GODWIN: I want to review some of the information 24 you provided to them. 25 Did you provide a table showing the simulated flows at CAPITOL REPORTERS (916) 923-5447 10760 1 Vernalis by month for the period 1922 through 1994? 2 MR. ARORA: I think so, yes, provided that 3 information. 4 MR. GODWIN: Did you also provide them a table showing 5 simulated water quality at Vernalis for that same time 6 period? 7 MR. ARORA: Right, uh-huh, yes. 8 MR. GODWIN: Did you provide a table showing the 9 simulated flows for the tributaries near the confluence with 10 the San Joaquin River and simulated flow upstream of the 11 Merced River? 12 MR. ARORA: I believe, yes. 13 MR. GODWIN: Why was this information needed for their 14 studies? Do you know? 15 MR. ARORA: My understanding was they were going to do 16 another step of modeling, doing what they call a SJRIO 17 model, a separate model for salinity calculations at 18 different locations in the San Joaquin system. 19 C.O. STUBCHAER: Could you pull the microphone just a 20 little closer and put it a little over to the left. 21 MR. GODWIN: In regards to the recirculation study that 22 they were doing, they needed to know, then, how much 23 additional flow was going to be required for recirculation 24 after water quality needs had already been met; is that 25 right? CAPITOL REPORTERS (916) 923-5447 10761 1 MR. ARORA: I believe so. 2 MR. GODWIN: Could I have the first overhead. 3 I have a table here that is labeled for identification 4 purposes as SJRGA 100. The title of this table is "Total 5 San Joaquin at Vernalis." 6 Was this table generated as a result of the DWRSIM 7 Study 468A that you ran? 8 MR. ARORA: Yes, please. 9 MR. GODWIN: Was this one of the tables that you 10 provided to Ms. Kipps and Mr. Grober? 11 MR. ARORA: Yes, please. 12 MR. GODWIN: What does this table show? 13 MR. ARORA: As labeled, this is earlier flow at 14 Vernalis as simulated by the model for period, I guess, 15 starting water year '22. Go down all the way down to water 16 year '94, which is San Joaquin simulation. 17 This is a monthly, mean monthly, flow at Vernalis in 18 cubic feet per second at Vernalis. 19 MR. GODWIN: This table was based on the assumptions 20 that we just discussed; is that correct? 21 MR. ARORA: Yes. 22 MR. GODWIN: The next table, please. 23 This table is labeled for identification as SJRGA 101, 24 and titled "Salinity at Vernalis." 25 Was this table generated as a result of your DWRSIM CAPITOL REPORTERS (916) 923-5447 10762 1 Study 468A? 2 MR. ARORA: That's right. 3 MR. GODWIN: Was this table included in the information 4 that you provided to Ms. Kipps and Mr. Grober? 5 MR. ARORA: Yes, please. 6 MR. GODWIN: What does this table show, Mr. Arora? 7 MR. ARORA: As the label there say, model computed 8 number which shows the salinity at Vernalis. Again, you 9 have mean monthly values for 73-year simulation for water 10 year '22 through water year '94. 11 MR. GODWIN: Again, this table used those same 12 assumptions we talked about earlier? 13 MR. ARORA: Yes, please. 14 MR. GODWIN: The next, please. 15 This next overhead shows Table 3 from staff Exhibit 7E 16 which is the 1995 Water Quality Control Plan for the San 17 Francisco Bay Sacramento-San Joaquin Delta Estuary. 18 Do you recognize this page? 19 MR. ARORA: Yes, please. 20 MR. GODWIN: What does this show under the compliance 21 location labeled San Joaquin River at Airport Way Bridge, 22 Vernalis? 23 MR. ARORA: It gives you really under different year 24 types the flow objectives under different monthly times. 25 You can see those numbers we have in cfs. CAPITOL REPORTERS (916) 923-5447 10763 1 MR. GODWIN: Those are, as you understand it, those are 2 the flow objectives in the 1995 Water Quality Control Plan? 3 MR. ARORA: Yes, please. 4 MR. GODWIN: Next table, please. 5 C.O. BROWN: Yes, Mr. Chairman. 6 C.O. STUBCHAER: Mr. Brown. 7 C.O. BROWN: The salinity levels that you derived to 8 make these tables up, the modeling, does the relationship 9 with flow -- or what was the relationships that made up 10 salinity or actual readings? 11 MR. ARORA: We have relationship in the model which 12 relates flow and salinity. That relationship we have used 13 for a while provided by a group of modeling agencies, 14 including the Board staff a while back. 15 C.O. STUBCHAER: Is the assumption, as a for instance, 16 if you've got 1200 cfs flowing, that your salinity is going 17 to be 1000? 18 MR. ARORA: I don't -- 19 C.O. BROWN: As an example, regardless of the source? 20 MR. ARORA: No. What we have done here is, this is the 21 final salinity at Vernalis table you saw. We have 22 relationship at Maze Station, which is upstream of the 23 confluence of Stanislaus. 24 C.O. BROWN: My question is this: Just a real quick 25 cursory review here, you've got a thousand parts per million CAPITOL REPORTERS (916) 923-5447 10764 1 of salinity in February and 4861 in 1988, and the flows are 2 all at 1200 plus cfs. 3 MR. ARORA: Those flows are at Vernalis. 4 C.O. BROWN: So the question is: How did you arrive at 5 a thousand parts per million? Are they actual measurements 6 or correlated just with the flows? How did the model -- how 7 did you determine that it is a thousand parts per million in 8 a for instance in those three years? 9 MR. ARORA: Two-step procedure, Mr. Brown. It is a 10 relationship we have in the model at Maze Station. Once we 11 have the flow and salinity relationship, use to compute 12 salinity off that water coming down at Maze Station. Then 13 we do some blending of water coming down Stanislaus, and 14 then we have other piece of flow, also called accretion, 15 below Godwin Dam. There is a different comparison of flow. 16 We mix them and blend it. 17 And when salinity comes out, if we are not meeting 18 standards, go back and add water from New Melones to arrive 19 at salinity objective of 1.2 to 1000. So, that includes 20 some additional release we might have made to meet that 21 water quality objective. 22 C.O. BROWN: Well, My concern is like certainly in 23 1988 and on, there is a lot of work that was being done in 24 tailwater management and subsurface drainage. I would have 25 expected some difference in the latter years as compared to CAPITOL REPORTERS (916) 923-5447 10765 1 the earlier years. And the earlier years, when there was no 2 tailwater recovery or holding of the subsurface drainage 3 waters back, that also contributes to the increase in 4 salinity in the early years. 5 My question is: It seems like there should be an 6 effect on that in the latter years. But the analysis here 7 doesn't show any change. It shows the same 1000 parts per 8 million salinity for 1948, 1961 and 1988. And in the months 9 of February they are all around 1200 cfs. No change. 10 MR. ARORA: In the study we are simulating as if we are 11 sitting at a given level of development. We don't go back 12 historically and look at what happened then. 13 In any simulation study we have to make assumption that 14 we are sitting at today's level development, and we are 15 looking at what these hydraulic conditions will do to these 16 operational we are making in the simulation study. Even 17 though they are historically different years, what we are 18 looking at is same level of development. 19 Now, we have at that level of development what we have 20 used as one relationship. We have for flow salinity at 21 Maze. One for irrigation and one for nonirrigation, two 22 relationships. Here we are comparing historical numbers, 23 two time periods. It's not quite true in a study because we 24 are looking at a level which is future. 25 C.O. BROWN: You are taking today's standards and then CAPITOL REPORTERS (916) 923-5447 10766 1 projecting back in this analysis of what it would have been 2 but with today's operations? 3 MR. ARORA: That is exactly right. 4 C.O. BROWN: Thank you, Mr. Chairman. 5 Ms. Forster. 6 MEMBER FORSTER: I just have a little further question 7 on that. Why would it be a thousand in the rainy season and 8 then go down to 700 in the drier season? You think it would 9 be opposite. You would think that you would have dilution 10 and flushing and better numbers versus higher numbers. I 11 just don't understand. 12 MR. GODWIN: Ms. Forster, if I could ask a few 13 questions of Mr. Arora, I think I could clear up your -- 14 MEMBER FORSTER: Okay. 15 MR. GODWIN: If you don't mind. 16 MEMBER FORSTER: Okay. 17 MR. GODWIN: The times when there is 700 micromhos per 18 centimeter standard versus a thousand, that reflects the 19 different water quality objectives during the different 20 times of the year; is that correct? 21 MR. ARORA: Yes. 22 MR. GODWIN: On this table when we see a number as 23 exactly 700 or exactly 1000, is that because the standard 24 wasn't being met and additional water quality releases were 25 made from New Melones to bring it up to the -- or actually CAPITOL REPORTERS (916) 923-5447 10767 1 bring the water quality down to the level required under the 2 Water Quality Control Plan? 3 MR. ARORA: That's right. The study attempts to meet 4 those water quality objectives by making releases, water 5 releases, to meet objective. 6 MEMBER FORSTER: Then I have one more question. 7 C.O. STUBCHAER: Yes. 8 MEMBER FORSTER: So, where you have the charts that 9 show the real time stuff, and is this just a scenario where 10 you are showing how you are trying to meet the standard? 11 How do you know what really is going on there? 12 MR. ARORA: These information what you have seen are 13 modeled outputs. It is not real time. 14 MEMBER FORSTER: Does somebody have the real time? 15 MR. ARORA: I don't. I just study what is scenarios. 16 I don't have real time information. 17 C.O. STUBCHAER: Are you talking about real time or 18 historic? 19 MEMBER FORSTER: I find modeling intriguing. I always 20 want to know what really is happening. I understand how you 21 do this and why you do it. But I just am asking is it 22 really a thousand, then, and is it really 700 or is that 23 just what -- input in, input out? We must -- I will be 24 quiet and I am sure we will find this out as we go along. 25 C.O. STUBCHAER: Mr. Del Piero. CAPITOL REPORTERS (916) 923-5447 10768 1 MEMBER DEL PIERO: Has your modeling been adjusted to 2 take into consideration the months in late '80s and early 3 '90s when you didn't meet the requirements? 4 MR. ARORA: In this study we met always. So we are not 5 trying to mimic the real historical impression. We are 6 saying we are sitting at future level and our best guess is 7 based accretion/depletion happening. We say get water from 8 New Melones if they are short of water quality. 9 MEMBER DEL PIERO: What is your assumption in terms of 10 deliveries? 11 MR. ARORA: For Stanislaus? 12 MEMBER DEL PIERO: Maybe that was given earlier. Did I 13 miss it? 14 MR. ARORA: We assume 600 for Oakdale and a thousand 15 San Joaquin and 155 for CVP contract, which is a maximum 16 number. We go down -- we simulate. And whatever happens, 17 the rules we have. 18 MEMBER DEL PIERO: So then, maybe I've got the same 19 problem Ms. Forster has. 20 If you assumed the maximum numbers and you know at 21 least in the near history that you weren't able to achieve 22 the actual deliveries without failing to meet the 23 standards, why does the model not take that into 24 consideration? 25 MR. ARORA: In certain years we do apply hard facts in CAPITOL REPORTERS (916) 923-5447 10769 1 the study. So, 600 is maximum. 2 MEMBER DEL PIERO: Which years did you apply the 3 reductions, then? 4 MR. ARORA: There are certain rules we used. I don't 5 have information, but we would need to use -- I think we 6 went for 3-, 400 -- if I remember correctly, 400 certain 7 years for Oakdale, South San Joaquin, just from memory. 8 Certain years we did go down below 600 and, of course, we go 9 to zero for CVP contracts many, many years in the study. 10 C.O. STUBCHAER: Maybe, Mr. Godwin, you can reask the 11 question about present day conditions being placed on 12 historic hydrology and how this isn't intended to mimic what 13 happened in the past. 14 MEMBER DEL PIERO: Jim, I understand that. I really 15 do. The reason I am asking the question is I am trying to 16 figure out just exactly how the model was constructed and 17 whether or not the model's constructed predicated upon the 18 potential for maximum deliveries or the model was predicated 19 upon actual deliveries and deficiency equivalent or 20 violations and deficiency, both, that, in fact, have taken 21 place. I wanted to -- I wanted to find out whether or not 22 the model's been adjusted to take into consideration those 23 '90, '91 -- I don't know we had a lot of deficiencies, 24 violations of the standard. Apparently that is not the 25 case. CAPITOL REPORTERS (916) 923-5447 10770 1 C.O. STUBCHAER: Maybe the question could be asked: 2 Does the model need to be adjusted, or did the model 3 generate the required output, whether it was devised to 4 consider all the calibrations? 5 MEMBER DEL PIERO: I am sure it was generated in the 6 required output. The question is based on the other side of 7 the equation whether or not the desired output corresponded 8 with what actually was. 9 C.O. STUBCHAER: It's not -- I am sorry, I can't 10 testify. It is my intent -- 11 MEMBER DEL PIERO: I understand it projects what the 12 desired output is. The question is whether or not the 13 desired output is physically capable of being delivered. 14 C.O. STUBCHAER: Let's go back to Mr. Godwin. 15 Mr. Brown. 16 C.O. BROWN: I think it might be helpful with the 17 concerns we have here, too, how you arrived at them, to take 18 another step back and tell us why you are doing this. What 19 is the objective here? What are you pointing out? 20 MR. GODWIN: We aren't there yet. I am still laying 21 some of the background. 22 C.O. BROWN: I understand. Just maybe -- 23 MR. GODWIN: We are this close. 24 C.O. STUBCHAER: Board Members, perhaps we ought to 25 allow Mr. Godwin to continue his line of questioning and CAPITOL REPORTERS (916) 923-5447 10771 1 save the questions for a little later, see if they are 2 answered in the process of his testimony. 3 MR. GODWIN: Let me just follow up on some questions 4 that Board Member Del Piero raised. The assumptions that 5 were used in the model were assumptions that were agreed to 6 by the study group that was looking at recirculation; is 7 that right? 8 MR. ARORA: Yes. 9 MR. GODWIN: The deficiencies that were applied to New 10 Melones operations, those deficiencies were provided to you 11 by the Bureau of Reclamation; is that correct? 12 MR. ARORA: Yes. Before we start the process of doing 13 study we met several times with Board staff and other 14 modeling staff and interested parties, including Bureau. We 15 were given a set of assumptions to be used in the study, 16 which has those rules to cut back deliveries to the locals 17 within the Stanislaus system. 18 MR. GODWIN: In dry years there were deficiencies 19 imposed on Oakdale and South San Joaquin Irrigation 20 Districts; is that correct? 21 MR. ARORA: That is right. 22 MR. GODWIN: There were deficiencies imposed on the CVP 23 contractors? 24 MR. ARORA: Yes. 25 C.O. BROWN: A question. I thought Oakdale and South CAPITOL REPORTERS (916) 923-5447 10772 1 San Joaquin had the first rights out of New Melones and they 2 were satisfied first. That is not right? 3 MR. ARORA: But still there are some rules when the 4 inflow to New Melones is below a certain number, they get 5 cut back. They are the first one, but there are some 6 conditions under which they take cutbacks. 7 MR. GODWIN: In your study New Melones was able to meet 8 its contractual water rights settlement commitments and 9 water quality requirements without going below a certain 10 level; is that correct? 11 MR. ARORA: Like I said, the rules we have for 12 delivering contractors and other, those rules the model did 13 not violate the operations status of Stanislaus system. We 14 took care of their needs and water quality needs with New 15 Melones Reservoir. 16 MR. GODWIN: The last table, please. 17 This last table I have identified as an exhibit, San 18 Joaquin River Group Authority 102. This was previously 19 shown earlier as Exhibit 29. So I think there might be some 20 confusion with this. 21 C.O. STUBCHAER: Your voice is trailing off. 22 MR. GODWIN: I'm sorry. Sort of talking to myself. 23 Did you provide this table to Ms. Kipps and Mr. Grober? 24 MR. ARORA: Yes, please. 25 MR. GODWIN: What does this table show? CAPITOL REPORTERS (916) 923-5447 10773 1 MR. ARORA: At that time this really is the additional 2 water needed to meet the '95 flow objectives. This really 3 is flow objectives. 4 C.O. BROWN: Objection. Feet or cfs? 5 MR. ARORA: These are acre-feet. Here are thousand 6 acre-feet. 7 MR. GODWIN: Now, the title says, "The May 1995 Water 8 Quality Control Plan"; that is referring to the Water 9 Quality Control Plan that was adopted in May 1995? 10 MR. ARORA: Right. 11 MR. GODWIN: This table then represents the amount of 12 additional water that would be required to meet the flow 13 objectives for the Water Quality Control Plan over and above 14 the flows that were provided for the water quality purposes; 15 is that right? 16 MR. ARORA: As simulated by our models. These are 17 model information. 18 MR. GODWIN: In terms of the assumptions used in DWRSIM 19 Study 468A, is it correct that this table would be the 20 amount of additional water provided through recirculation 21 that would be required to fully achieve the flow objectives 22 of the Water Quality Control Plan? 23 MR. ARORA: That's true, yes. 24 MR. GODWIN: Let's look at some of the values on this 25 table. Does this table illustrate the number -- CAPITOL REPORTERS (916) 923-5447 10774 1 C.O. BROWN: Clarification, Mr. Chairman. 2 I am sorry to interrupt you, Mr. Godwin. 3 You said that is the amount of water that would be 4 needed to meet the -- through the recirculation program? 5 MR. ARORA: It is to meet flow objectives; that means 6 water for recirculation if that is the proposal. 7 C.O. BROWN: Is that the total amount of water that is 8 needed, the summation of all of that, or if you go through 9 the recirculation, is part of that or all of the recovered? 10 MR. ARORA: This is incremental quantity you need for 11 meeting flow objective. 12 C.O. BROWN: It is acre-feet. It is not flow. 13 MR. ARORA: Monthly number. So much volume of water in 14 that month. 15 C.O. BROWN: The impression you left me, that is the 16 quantity of water that is needed to meet the flow objective 17 through recirculation. Is that correct? 18 MR. ARORA: This is the additional quantity over and 19 above the base flow we have in the study. We are short by 20 these quantities. 21 C.O. BROWN: The clarification is this: Is this a 22 total cost in water or does the recirculation -- is there a 23 quantity of water that you recirculate less than that total 24 amount that meets the objective? 25 MR. ARORA: This is like cost you need water for CAPITOL REPORTERS (916) 923-5447 10775 1 meeting flow objectives, additional from source. In this 2 case the recirculation water coming down. This is 3 additional flow we need to meet flow objective. 4 C.O. BROWN: You are talking acre-feet, not flow? 5 MR. ARORA: That's right. 6 C.O. BROWN: I'm talking acre-feet. What I want to 7 know, is this a cost in acre-feet with the recirculation 8 program, or with the recirculation program do you 9 recirculate enough water to where this is not the cost? 10 How much water is lost to the system is the question, this 11 quantity or a lesser quantity? 12 MR. ARORA: These are the quantities you need to meet 13 flow objective at Vernalis, and I leave it there, because I 14 don't do the recirculation in my study. I just provide 15 information as to how much water you need to meet your flow 16 objective. 17 C.O. BROWN: Your statement was, this was the cost, I 18 believe. 19 MR. ARORA: I said additional flow you need to meet 20 water flow objectives. 21 C.O. STUBCHAER: Let's allow Mr. Godwin. 22 MR. GODWIN: Could you put Exhibit 100 back up on 23 there, please. I think I can clear this up. 24 Mr. Arora, this table was generated with DWRSIM Study 25 468A; is that correct? CAPITOL REPORTERS (916) 923-5447 10776 1 MR. ARORA: Yes, please. 2 MR. GODWIN: This shows the monthly flow at Vernalis in 3 cfs; is that correct? 4 MR. ARORA: That's right. 5 MR. GODWIN: This table was generated using the 6 assumptions that water quality would be met at Vernalis, but 7 without regard in trying to meet the flow objective at 8 Vernalis; is that correct? 9 MR. ARORA: That's right. 10 MR. GODWIN: Then to generate the table that is Exhibit 11 102, you basically compared the flows on this table with the 12 flow requirements in the plan, and where there was a 13 deficit, then that was the amount of additional water that 14 would be needed to meet the 1995 Water Quality Control Plan 15 flow objectives; is that correct? 16 MR. ARORA: Right. That is the way this number is 17 supposed to mean, increment to meet the flow objectives. 18 MR. GODWIN: This additional water, then, could come 19 from any source, whether from recirculation or releases from 20 east side tributaries or from New Melones? You didn't 21 specify the source of this additional water; is that 22 correct? 23 MR. ARORA: That's right. 24 MR. GODWIN: Let's look at some of the numbers on this 25 table. The average annual amount of water that would be CAPITOL REPORTERS (916) 923-5447 10777 1 required to meet the flow objectives is approximately 82,000 2 acre-feet; is that correct? 3 MR. ARORA: Yes. 4 MR. GODWIN: Let's look at some of the years on this 5 table. First of all, let's look at 1993. I will represent 6 that 1993 was a wet year. And what does this show? What 7 does this table show as far as the amount of additional 8 water needed to meet flow objectives? 9 MR. ARORA: This shows that for this water year, 1993 10 you selected, you need additional flow from some source of 11 311,000 acre-feet for the whole year to meet the flow 12 objectives at Vernalis. 13 MR. GODWIN: Most of that water is required in the 14 April/May pulse flow period? 15 MR. ARORA: Yes, that's true; 165 for April and 85 for 16 May. 17 MR. GODWIN: Let's look at another year, 1984. I will 18 represent to you that 1984 was an above normal water year 19 type. What do the results show here for 1984? 20 MR. ARORA: I believe it shows 178,000 acre-feet for 21 the water year. 22 MR. GODWIN: And, again, most of that water is required 23 during the April/May pulse flow period; is it not? 24 MR. ARORA: 52 in April, and I think that is April, and 25 May is 113. CAPITOL REPORTERS (916) 923-5447 10778 1 MR. GODWIN: Let's move on up to 1953. I will 2 represent to you that 1953 was a below normal water year 3 type. What do your results show for 1953? 4 MR. ARORA: I think it shows 190,000 acre-feet for this 5 water year. 6 MR. GODWIN: Again, most of that is being required for 7 the April/May pulse flow period; is it not? 8 MR. ARORA: That's right. 9 MR. GODWIN: And 1972? I will represent that 1972 was 10 a dry year. What do your results show for the year 1972? 11 MR. ARORA: Shows about 245,000 acre-feet. 12 MR. GODWIN: Again, most of that is required during 13 April and May? 14 MR. ARORA: I believe that is the case. 15 MR. GODWIN: This information you provided along with 16 the other information was a result of the DWRSIM Study 468A, 17 and you provided this information to Mr. Grober and Ms. 18 Kipps; is that correct? 19 MR. ARORA: That's right. 20 MR. GODWIN: Now, hypothetically if you were required 21 to simulate a recirculation operation that builds upon the 22 DWRSIM Study 468A, would you use a table similar to Exhibit 23 102 to reflect the timing and amount of recirculation water 24 that would be needed to meet the flow objectives? 25 MR. ARORA: Yes. That is monthly volumes you need. CAPITOL REPORTERS (916) 923-5447 10779 1 MR. GODWIN: Earlier we were looking at the water 2 quality results from 468A. And I just want -- we probably 3 went over this, but the results of that study show that 4 water quality was met in all months of all years; is that 5 correct? 6 MR. ARORA: In our study we showed we met the salinity 7 standards. 8 MR. GODWIN: What flow salinity relationship was DWRSIM 9 used to calculate the EC at Vernalis? 10 MR. ARORA: This data goes back a few years ago when we 11 had this issue, what should be used. And we met with quite 12 a few people, including Board staff, to give us some 13 guidance as to doing study like this, what kind of 14 relationship should be used. So, we came up with 15 relationship that relates salinity with flow. Again, the 16 effort was really headed by Board staff at the time, and we 17 have that flow/salinity relationship at Maze Station, which 18 is upstream of the confluence of Stanislaus. 19 MR. GODWIN: The flow salinity relationship, then, was 20 agreed to by Board staff and by DWR and was used? 21 MR. ARORA: And some other parties. 22 MR. GODWIN: Yes. 23 MR. ARORA: Yes. 24 MR. GODWIN: What if I told you that the SJRIO model 25 calculates San Joaquin River water -- excuse me, San Joaquin CAPITOL REPORTERS (916) 923-5447 10780 1 River salinity differently from DWRSIM? Does that mean that 2 SJRIO or DWRSIM more accurately measures water quality than 3 the other model? 4 MR. ARORA: These are two different models. I would 5 expect to be miracle if you can get the same numbers from 6 the different models. They are different formulations, and 7 I believe they are different numbers. I don't know which 8 one is more accurate. 9 MR. GODWIN: Have you performed any other analysis that 10 evaluates the ability of the Central Valley Project and 11 State Water Project to accommodate the recirculation 12 proposal based upon the results of the DWRSIM study? 13 MR. ARORA: For this study, we just provided 14 information, what was requested; that is, additional 15 quantities of water to meet flow objective. We didn't go 16 back and put in the DWRSIM model and operate the projects to 17 meet this type of flow requirements. So we did not do any 18 assimilation after this step. 19 MR. GODWIN: I have no more questions. 20 C.O. STUBCHAER: Thank you, Mr. Godwin. 21 Ms. Forster has a question. 22 MEMBER FORSTER: I have a question on the chart where 23 you show the below normal the dry and above normal and wet 24 years. I just would appreciate if you would explain to me 25 why the water cost in a wet year is more than the water cost CAPITOL REPORTERS (916) 923-5447 10781 1 -- the wet year you said was '93. Let's take the dry year 2 which was '72. Why is the water cost more in '93, a wet 3 year, than it is in '72, a dry year? 4 MR. ARORA: You really have to go back to the flow 5 objective we are trying to meet. If you have flow objective 6 which in wet year is much higher number, but that months 7 flow coming down -- you could have wet year but you don't 8 have flow every month of the year now. So the flow coming 9 down that particular month, April/May, is not enough to meet 10 the flow objective described in the plan. 11 MEMBER FORSTER: Okay. 12 MR. ARORA: So you have that deficit which we need from 13 additional sources. 14 MEMBER FORSTER: On paper this isn't very logical. When 15 you explain it, I understand. 16 I have a question before you leave this model. 17 Why is your model different from the SJRIO model? I 18 have this theme about sameness. So when people are 19 comparing, it's easier to understand that across the 20 Board. MR. ARORA: I don't have good answer for 21 that. But DWRSIM model is designed to do statewide 22 operations for projects. We have very simplistic view of 23 flow/salinity at Vernalis, whereas SJRIO goes much more 24 fine-tuned operation to Stanislaus and San Joaquin. 25 MEMBER FORSTER: Thank you. CAPITOL REPORTERS (916) 923-5447 10782 1 MR. GODWIN: If I could just follow up with a 2 question. DWRSIM and SJRIO were developed for entirely 3 different purposes; isn't that correct? 4 MR. ARORA: Yes. I think so. Because, like I said, 5 DWRSIM was designed to do statewide simulations starting 6 from reservoirs at Shasta, Oroville, all way up to 7 California Aqueduct, larger scale model. 8 MR. GODWIN: I will have some other witness that can 9 talk more about SJRIO. 10 MEMBER FORSTER: Thank you, Mr. Chairman. 11 C.O. STUBCHAER: Who wishes to cross-examine Mr. Arora? 12 Mr. O'Laughlin, Mr. Jackson. 13 Anyone else? 14 Mr. Jackson, you're heads. And it's tails, so Mr. 15 O'Laughlin. 16 ---oOo--- 17 CROSS-EXAMINATION OF 18 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 19 BY OAKDALE IRRIGATION DISTRICT 20 BY MR. O'LAUGHLIN 21 MR. O'LAUGHLIN: Morning. My name is Tim O'Laughlin, 22 and today's capacity I am going to be representing Oakdale 23 Irrigation District. 24 Specifically in regards to the baseline assumptions 25 that were used for the modeling, you stated you didn't use CAPITOL REPORTERS (916) 923-5447 10783 1 the Interim Operations Plan for New Melones; is that 2 correct? 3 MR. ARORA: That's right. 4 MR. O'LAUGHLIN: Did you have a flow restriction below 5 Godwin of 1,500 cfs for the spring pulse flow in your 6 modeling assumption? 7 MR. ARORA: Yes, we did. We did that, put that 8 assumption at the request they made on this small study. 9 MR. O'LAUGHLIN: Thank you very much. 10 I have no further questions. 11 C.O. STUBCHAER: Mr. Jackson. He just left. 12 Morning, Mr. Jackson. 13 MR. JACKSON: How are you? 14 ---oOo--- 15 CROSS-EXAMINATION OF 16 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 17 BY REGIONAL COUNCIL OF RURAL COUNTIES 18 BY MR. JACKSON 19 MR. JACKSON: I am Michael Jackson for the Regional 20 Council of Rural Counties. 21 When you did the model, sir, you made the assumptions 22 that you described here to the Board, based upon what you 23 were told to do? 24 MR. ARORA: That's right. 25 MR. JACKSON: Who, again, told you to make those CAPITOL REPORTERS (916) 923-5447 10784 1 assumptions? 2 MR. ARORA: Which assumptions we talking? There are a 3 lot of assumptions. 4 MR. JACKSON: The assumptions that were given to you to 5 prepare the model run, runs that are in front of us. This 6 was some committee? 7 MR. ARORA: Yes. A group of individuals which from 8 Board staff, and I am talking the modeling assumptions in 9 general. There are a lot of assumptions that you have to go 10 through. And for this particular study we have just few 11 changes for the study. However, we have assumptions which 12 we used for several studies requested by the Board staff. 13 They were carried over from those studies to this study. 14 MR. JACKSON: One of the assumptions was that you would 15 meet water quality standards at Vernalis at all times in all 16 year types? 17 MR. ARORA: For this study that was assumed that we are 18 not putting any other flow objective for New Melones. So, 19 therefore, water quality should be made all the time if we 20 have water in New Melones, which we happen to have in the 21 study. 22 MR. JACKSON: In the study there was water available in 23 New Melones to meet the flow standard? 24 MR. ARORA: That's right. 25 C.O. STUBCHAER: Excuse me, the flow standard or -- CAPITOL REPORTERS (916) 923-5447 10785 1 MR. JACKSON: Excuse me, the water quality standard. 2 MR. ARORA: The water quality standard, yes. 3 MR. JACKSON: In so doing, you cut back on every other 4 parameter, correct, water deliveries, water flow, everything 5 else in order to meet water quality standard? 6 MR. ARORA: The way model structure set up, you have 7 certain rules to cut back those people. So you cut back by 8 the rules. Those are in-basin demands. And we moved on 9 from upstream to downstream; that is, we start on top to 10 bottom. And whatever water is delivered and return flows 11 which come back to the system are available downstream, 12 also. We are looking for the -- towards the end we say, 13 "What else we need to meet water quality standard?" This is 14 last objective we impose. 15 It turned out in this case system did not go really 16 broke. That means New Melones did not go to zero, that we 17 had water for meeting all the objectives. 18 MR. JACKSON: So, you never did go broke? 19 MR. ARORA: In this study we did not go broke. 20 MR. JACKSON: So water quality standards can be met if 21 you follow the procedures that you followed in your 22 simulation? 23 MR. ARORA: That's what my study shows. 24 MR. JACKSON: Could you put up the third page of the 25 study, please? CAPITOL REPORTERS (916) 923-5447 10786 1 Actually, I am sorry, it's the additional water needed 2 to meet the water quality standards. 3 C.O. STUBCHAER: 102? 4 MR. JACKSON: Right. 5 Now this particular table is the cost of water needed 6 to meet the flow standards after you meet the water quality 7 standard? 8 MR. ARORA: This is additional water you need from some 9 source to meet the flow objectives on top of what the study 10 provided as the flows at Vernalis. 11 MR. JACKSON: So, the numbers that you have in the sum 12 show that every year, except six, there would be additional 13 water required to meet the 1995 Water Quality Control Plan? 14 MR. ARORA: You have additional quantities to meet the 15 flow objectives of the whole plan. 16 MR. JACKSON: You've already met the water quality? 17 MR. ARORA: We met the base condition study, yes. 18 MR. JACKSON: Whatever the cost was to meet water 19 quality from the cutback of the other obligations listed in 20 the simulation, are not listed on this table? 21 MR. ARORA: That's true, just for flow objectives. 22 MR. JACKSON: Is there any way to tell from these 23 tables how much you had to cut people back to meet the water 24 quality standard before this additional cutback? 25 MR. ARORA: Remember, these are not cutbacks. These CAPITOL REPORTERS (916) 923-5447 10787 1 are additional water you need. 2 MR. JACKSON: Additional water for the flow, but it is 3 a cutback from some other use? I am sorry, I used the -- 4 MR. ARORA: Depends how you are trying to meet the flow 5 objective. If the proposal is to go to recirculation, maybe 6 you are recirculating the same water. But -- 7 MR. JACKSON: The recirculation takes place -- the 8 recirculation examination takes place after this particular 9 table is in effect, does it not? I mean, this table is your 10 simulation of what it takes to meet the 1995 Water Quality 11 Control Plan no matter which alternative? 12 C.O. STUBCHAER: Mr. O'Laughlin. 13 MR. O'LAUGHLIN: Objection. Compound. He asked two 14 questions. 15 C.O. STUBCHAER: Your first one, when you talk about 16 the cutbacks, I am sure we never recovered from that. 17 MR. JACKSON: Let me go back. 18 These additional water -- this additional water 19 required to meet the Water Quality Control Plan standards 20 would be required under any alternative if the San Joaquin 21 system was operated under those assumptions? 22 MR. ARORA: Yes. 23 MR. JACKSON: It is not the cost of the recirculation 24 element. This would be what would be necessary for any 25 alternative if you were going to meet the standards? CAPITOL REPORTERS (916) 923-5447 10788 1 MR. ARORA: I believe so. 2 MR. JACKSON: So one could take this table and compare 3 it to all of the alternatives? 4 C.O. STUBCHAER: Mr. Jackson, I don't think the 5 alternatives have been defined. 6 MR. JACKSON: The alternatives in the Draft 7 Environmental Impact Report of the Board's. 8 C.O. STUBCHAER: All right. That wasn't specified. 9 MR. JACKSON: One could take this table and the 10 additional water needed to meet the 1995 Water Quality 11 Control Plan and compare it to any alternative in the Draft 12 Environmental Impact Report to evaluate water cost? 13 MR. ARORA: I think to great extent that is true. 14 However, depending upon the source of water you may have 15 certain salinity issues. But if you are getting freshwater 16 release, you probably may have different quality implication 17 of that. If you are recirculating from Delta waters, maybe 18 different water quality. 19 However, if you looking at flow objectives, I presume 20 that is true, that you need this kind of additional waters 21 to meet the flow objective. 22 MR. JACKSON: So to be -- let's just pick a year that 23 is up there on the board that we can see. I believe you 24 used 1954, which was a below normal year. The sum of water 25 needed, there's a line underneath it on the table that is on CAPITOL REPORTERS (916) 923-5447 10789 1 the screen, you would need 190.69 or 190,690 acre-feet for 2 the year 1950? 3 MR. ARORA: I believe that is 1953. 4 MR. JACKSON: 1953 -- 5 MR. ARORA: Yes. 6 MR. JACKSON: -- to meet the 1995 Water Quality Control 7 Plan flow standards at Vernalis? 8 MR. ARORA: That is true. 9 MR. JACKSON: That would be true whether or not you 10 were doing the recirculation alternative or any other 11 alternative; is that correct? 12 MR. ARORA: Like I said before, I believe this is a 13 true statement if you are not looking for water quality 14 implication due to this additional water source. 15 MR. JACKSON: Now, talking about the water quality 16 implication, is there a different water quality implication 17 depending upon whether the water comes from the Stanislaus 18 or the Merced? 19 MR. ARORA: I don't know. I would think if you are 20 making freshwater releases, they are probably similar in 21 water quality. 22 MR. JACKSON: Then is the water quality difference you 23 are talking about whether you meet them from using water 24 from the exchange contractors or from the Merced? 25 MR. ARORA: I am not too much water quality subject, CAPITOL REPORTERS (916) 923-5447 10790 1 but I would think that the source of water would control 2 your -- if you are getting the Delta water being used for 3 this purpose, it may have different water quality than 4 freshwater releases from reservoirs. 5 MR. JACKSON: Thank you, sir. 6 I have no further questions. 7 C.O. STUBCHAER: Staff have any questions? 8 MR. HOWARD: No. 9 C.O. STUBCHAER: Board Members? 10 Mr. Brown. 11 ---oOo--- 12 CROSS-EXAMINATION OF 13 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 14 BY BOARD MEMBERS 15 C.O. BROWN: Just to put it into perspective, if you 16 would light it up again. 17 What is the number? 18 MS. LEIDIGH: 102. 19 C.O. BROWN: Go back to 1953. If you take the 20 increment in April and May, I see that you need 67,000 21 acre-feet? 22 MR. ARORA: Yes. 23 C.O. BROWN: If I did the calculations correct, does 24 that turn out to be a thousand cfs for 30 days? 25 MR. ARORA: Yes. If you are looking for getting the CAPITOL REPORTERS (916) 923-5447 10791 1 water for 30 days. But our pulse flow objective are on 2 shorter time. For April we have 15 days. So, really, this 3 water has to come down over 15 days to meet flow objective. 4 C.O. BROWN: It is not 30 days? 5 MR. ARORA: The flow objective is 15 days in April. We 6 are modeling April 15 to May 15th, so we have flow 7 objective in April for 15 days. I am talking pulse flow 8 objectives are high numbers. So, I would believe most of 9 the water really has to come down in 15 days. 10 C.O. BROWN: So, we are talking about you need 67,000 11 acre-feet in 15 days, so it would be 2,000 cfs? 12 MR. ARORA: Something in that range. 13 C.O. BROWN: Okay. Thank you. 14 C.O. STUBCHAER: Do you have any redirect, Mr. Godwin? 15 MR. GODWIN: I just have a couple questions. 16 ---oOo--- 17 REDIRECT-EXAMINATION OF 18 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 19 BY MR. GODWIN 20 MR. GODWIN: Let's use 1953 as an example. We have a 21 total of additional water needed was 191,000; is that 22 correct? 23 MR. ARORA: Seems like. 24 MR. GODWIN: And this was the additional water after 25 all the water quality objectives were met; is that right? CAPITOL REPORTERS (916) 923-5447 10792 1 MR. ARORA: Yes, please. 2 MR. GODWIN: If you could put up Exhibit 101, please, 3 Dan. 4 And let's look at 1953. In the months of June, July 5 and August would -- the amount there is 700 micromhos per 6 centimeter; is that correct? 7 MR. ARORA: Yes. 8 MR. GODWIN: You testified earlier that that indicates 9 that the water quality objective was not being met, so 10 additional water was being released from New Melones to meet 11 the water quality objectives; is that correct? 12 MR. ARORA: I believe so. These three months are not 13 objective water quality so we had to make releases. 14 MR. GODWIN: If you were to combine this table with the 15 additional water table, which was Exhibit 102, you would see 16 that the actual water cost is a little bit higher; is that 17 correct? 18 MR. ARORA: If you are talking about getting the 19 incremental water release for meeting water quality, that is 20 a separate table. To give you total you have to add those 21 two tables up, so total water needed to meet water quality 22 and flow objectives. These are the salinity tables. They 23 don't show you additional flow, how much we needed for 24 meeting water quality objectives. 25 MR. GODWIN: Thank you. CAPITOL REPORTERS (916) 923-5447 10793 1 C.O. STUBCHAER: Mr. O'Laughlin, let me ask: Are you 2 going to recross? 3 MR. O'LAUGHLIN: Yes. 4 C.O. STUBCHAER: I am going to ask first: Who wishes 5 to recross? 6 Mr. O'Laughlin. 7 Mr. Jackson, do you have your hand up? 8 MR. JACKSON: Yes, I did. 9 C.O. STUBCHAER: Mr. O'Laughlin. 10 ---oOo--- 11 RECROSS-EXAMINATION OF 12 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 13 BY OAKDALE IRRIGATION DISTRICT 14 BY MR. O'LAUGHLIN 15 MR. O'LAUGHLIN: Very quickly. In regards to the 1953, 16 then, when we look at June, July and August, and we see that 17 the standard is being met that way, you said additional 18 water in your base case would be coming out of New Melones; 19 is that correct? 20 MR. ARORA: Base study will have a water quality 21 release in these three months to meet our water quality 22 standards. 23 MR. O'LAUGHLIN: From New Melones. 24 MR. ARORA: Yes. 25 MR. O'LAUGHLIN: Is there a chart someplace within the CAPITOL REPORTERS (916) 923-5447 10794 1 -- at DWR that would, if you took this chart, would tell you 2 how much add water was coming from New Melones to meet water 3 quality in the months of June, July and August? 4 MR. ARORA: I believe we can get that information. 5 MR. O'LAUGHLIN: Then if we -- following on Mr. 6 Godwin's question, then if we took that table, which is over 7 at DWR, and added it to the Table 102, we would truly see 8 the amount of water needed to meet the 1995 Water Quality 9 Control Plan standards and objectives at Vernalis; is that 10 correct? 11 MR. ARORA: Yes. I believe so. 12 MR. O'LAUGHLIN: Thank you very much. 13 I have no further questions. 14 C.O. STUBCHAER: Mr. Jackson. 15 ---oOo--- 16 RECROSS-EXAMINATION OF 17 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 18 BY REGIONAL COUNCIL OF RURAL COUNTIES 19 BY MR. JACKSON 20 MR. JACKSON: Following up on what Mr. O'Laughlin 21 said, anytime, on this, the chart that is on the screen, 22 Table 2, I believe that is 102 -- 101. Anytime on this 23 screen that we see 1000 or 700, there is an additional water 24 cost above the flow cost that is required out of New Melones 25 to meet the water quality standard at Vernalis; is that CAPITOL REPORTERS (916) 923-5447 10795 1 right? 2 MR. ARORA: That is true. That these months we need 3 additional water. That why we just add the standard. 4 MR. JACKSON: If we went down to 1990 and looked at the 5 months of December, January and February, where it says 6 1000, some amount of additional water would be required in 7 those months to meet the water quality standard in the Delta 8 or at Vernalis? 9 MR. ARORA: At Vernalis, yes, please. 10 MR. JACKSON: In the same year, 1990, then in the 11 months of April, May, June, July and August, some other 12 additional amount of water would be necessary to meet the 13 water quality standard? 14 MR. ARORA: I don't recall looking at those numbers, 15 but there could be months where you need water for flow 16 objective. 17 MR. JACKSON: In the year 1990 -- 18 MR. ARORA: Yeah. 19 MR. JACKSON: -- we indicated that the thousand in the 20 months of December, January and February indicated the need 21 for additional water. We don't know how much? 22 MR. ARORA: For water quality purposes? 23 MR. JACKSON: For water quality purposes. 24 MR. ARORA: Yes. 25 MR. JACKSON: The same thing is true of the 700 number CAPITOL REPORTERS (916) 923-5447 10796 1 for the five months beginning in April; we need additional 2 water. We don't know how much? 3 MR. ARORA: Yes, that is true. 4 MR. JACKSON: Is this sort of the way to determine, 5 looking back to determine whether we violated standards in 6 1990 in all of those months? 7 MR. ARORA: Again, I think we are keeping in mind that 8 this is model study which tries to do the best it can at a 9 given level of development. It normally is difficult to 10 match the history with this simulated information, but this 11 should be pretty close, I would think. 12 MR. JACKSON: So, this is the best attempt that DWR can 13 make to determine, assuming that the projects were operated 14 under the assumptions, looking backward, how often we 15 violated? 16 MR. O'LAUGHLIN: Objection. Assumes facts not in 17 evidence. He said "projects." The basis -- 18 MR. JACKSON: Excuse me. 19 C.O. STUBCHAER: Sustained. 20 MR. JACKSON: That is true. Let me try that again. 21 MR. O'LAUGHLIN: I am going to object if we keep going 22 because this is outside the scope of redirect. The redirect 23 is very limited. It had two minor questions about add 24 water. It had nothing to do with violating standards at 25 Vernalis. He had his chance and he missed it. CAPITOL REPORTERS (916) 923-5447 10797 1 C.O. STUBCHAER: The last part I will ignore. 2 MR. JACKSON: There will be many more chances, and I 3 will remember that. 4 C.O. STUBCHAER: But I think the first part was 5 correct, Mr. Jackson. 6 MR. JACKSON: Thank you. 7 C.O. STUBCHAER: Staff? 8 Board Members? 9 Thank you, Mr. Arora, for your participation. 10 MR. ARORA: Thank you. Sure. 11 C.O. STUBCHAER: Mr. Godwin. 12 MR. GODWIN: I would like to call Mr. Grober and Ms. 13 Joanne Kipps, please. 14 C.O. STUBCHAER: Morning. 15 MR. GODWIN: Ms. Kipps and Mr. Grober, have you been 16 sworn in yet? 17 MR. GROBER: I testified previously in this hearing. I 18 have. 19 MS. KIPPS: I have not. 20 (Oath administered by C.O. Stubchaer.) 21 ---oOo--- 22 DIRECT-EXAMINATION OF 23 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 24 BY MR. GODWIN 25 MR. GODWIN: Have you two appeared here today by CAPITOL REPORTERS (916) 923-5447 10798 1 subpoena? 2 MR. GROBER: Yes. 3 MS. KIPPS: Yes. 4 MR. GODWIN: Mr. Arora just provided you with an 5 explanation -- 6 C.O. STUBCHAER: Have them spell their name for the 7 Court Reporter. 8 MR. GODWIN: Could you give your name for the record. 9 MR. GROBER: My name is Leslie Franklin Grober, 10 G-r-o-b-e-r. 11 MS. KIPPS: Joanne Lorraine Kipps, K-i-p-p-s. 12 MR. GODWIN: Mr. Arora just provided you with an 13 explanation of the basic assumptions that were used in 14 DWRSIM Study 468A and results that that study produced and 15 what was provided to Mr. Grober and Ms. Kipps who then were 16 responsible for performing the SJRIO studies that were 17 incorporated into the exhibit identified as South Delta 18 Water Agency Exhibit Number 12. I am going to now have Ms. 19 Kipps and Mr. Grober explain how they incorporated that 20 study into their SJRIO studies. 21 Ms. Kipps, did you author the, I guess it is, 22 preliminary draft report entitled "SJRIO Studies of San 23 Joaquin River Recirculation and Reoperation of the Wetland 24 Discharge and Tile Drainage"? 25 MS. KIPPS: Yes. CAPITOL REPORTERS (916) 923-5447 10799 1 MR. GODWIN: For the record, that report is identified 2 as South Delta Water Agency Exhibit Number 12. 3 Ms. Kipps, could you briefly describe the scope of the 4 investigation. 5 MS. KIPPS: The scope was to explore on a model 6 simulation basis any kind of water quality changes or 7 impacts that would result from using Delta water to 8 supplement the flows in the San Joaquin River to achieve 9 compliance with the water quality -- water flow objective. 10 We made the assumption that Delta water would be transported 11 via the Delta-Mendota Canal and the Newman Wasteway would be 12 used to discharge that water into the San Joaquin around the 13 confluence of the Merced. So we used a model that was 14 developed by the State Board, San Joaquin River Input-Output 15 or SJRIO, to calculate the flow and the salinity at various 16 points, one of which being the Vernalis point. 17 And so then we made a base case where we had no 18 reoperation. We used the values that DWRSIM provided for 19 the various tributary inputs to the main stem of the San 20 Joaquin River. And then on the -- from that base case we 21 changed the parameters of the model. We added DMC 22 recirculation in one scenario, and then we would compare how 23 those results differed or were the same as the base case. 24 MR. GODWIN: Another objective of your study was also 25 to look -- to evaluate reoperating tile drainage releases or CAPITOL REPORTERS (916) 923-5447 10800 1 wetland discharges into the San Joaquin River; is that 2 correct? 3 MS. KIPPS: That is correct. 4 MR. GODWIN: Did your investigation involve running a 5 single study or did you run multiple studies? 6 MS. KIPPS: Could you define what you mean by "study"? 7 MR. GODWIN: For instance, on Table 3 there are several 8 different runs listed; were those different studies that 9 were run evaluating different parameters? 10 MS. KIPPS: There were different runs. I wouldn't call 11 them studies. When you run a model, it is a computer 12 program, and it is all based on the input that you put into 13 the computer program. It does its run. It calculates all 14 the values that a model does and it generates the output. 15 The various runs are essentially changes in the input 16 that go into a model. So we did numerous runs where we 17 would change the inputs and see what the results were. 18 MR. GODWIN: I will try to call those runs and not 19 studies. 20 Would you say that the two major parameters you changed 21 for the various runs were, first of all, the timing of the 22 recirculation flows and, secondly, the timing of the 23 drainage and wetlands discharge flows? 24 MS. KIPPS: That's correct. 25 MR. GODWIN: And then, what parameters were used to CAPITOL REPORTERS (916) 923-5447 10801 1 display the results of the runs? If I could follow that up, 2 Table 7 looks like you compared the results using New 3 Melones -- additional New Melones water and water quality 4 exceedances as the two parameters to compare the results; is 5 that correct? 6 MS. KIPPS: That is correct. 7 MR. GODWIN: I would like to start, first of all, and 8 look at the information that Mr. Arora provided to you and 9 review some of that data. 10 Did he provide you with a table showing the simulated 11 flows at Vernalis by month for the period 1922 through 1994? 12 MS. KIPPS: Yes, he did. 13 MR. GODWIN: Did he provide you with a table showing 14 the simulated water quality at Vernalis for that same time 15 period? 16 MS. KIPPS: Yes he did. 17 MR. GODWIN: Did he provide you a table showing the 18 simulated flows for the tributaries near their confluences 19 with the San Joaquin River and the simulated flow upstream 20 of the Merced River? 21 MS. KIPPS: Yes. 22 MR. GODWIN: Finally, he also provided a table 23 representing the amount of additional water needed to meet 24 the flow objective for the 1995 Water Quality Control Plan? 25 MS. KIPPS: Yes. CAPITOL REPORTERS (916) 923-5447 10802 1 MR. GODWIN: Those studies were identified for those -- 2 that data was the result of a study that he performed that 3 was entitled "DWRSIM Study 468A"; is that correct? 4 MS. KIPPS: Yes. 5 MR. GODWIN: Is it your understanding that this DWRSIM 6 Study 468A provided an operation that would meet the water 7 quality objectives at Vernalis that did not necessarily meet 8 the flow objectives? 9 MS. KIPPS: That is what I understood, yes. 10 MR. GODWIN: Looking at Page 2 of your report, in the 11 third paragraph of that report, there is some discussion 12 there, DWRSIM Study 468A and Study 469. The description 13 seems to suggest that DWRSIM Study 469 was used, but we just 14 heard Mr. Arora testify that it was DWRSIM Study 468A. 15 MS. KIPPS: Run 469 was the input to run 469. DWR run 16 469 were changed and the resulting run they called 468A. 17 They weren't the same run. 18 MR. GODWIN: But 469 wasn't used for your purposes; is 19 that correct? 20 MS. KIPPS: No. 21 MR. GODWIN: You wouldn't have any reason to contradict 22 what Mr. Arora represented earlier about the assumptions or 23 results of this study? 24 MS. KIPPS: No. 25 MR. GODWIN: Your expertise and Mr. Grober's expertise CAPITOL REPORTERS (916) 923-5447 10803 1 is in the use of the SJRIO model; is that correct? 2 MS. KIPPS: That's right. 3 MR. GODWIN: Your draft report describes what the SJRIO 4 model is and how it was used; is that correct? 5 MS. KIPPS: Yes. 6 MR. GODWIN: Mr. Grober, I believe, the SJRIO Model is 7 described as a mass balance water quality model? 8 MR. GROBER: Yes, that is correct. 9 MR. GODWIN: Briefly, could you tell us what that 10 means? 11 MR. GROBER: It is a fairly simple mass balance model. 12 It is not looking at the dynamics of the system. But it 13 works on a monthly time step, considers inputs and outputs 14 along, this particular case, a 60-mile reach of San Joaquin 15 River from Lander Avenue to Vernalis and considers on a 16 monthly time step the flow in the river and the water 17 quality. 18 MR. GODWIN: Does the SJRIO model simulate operations 19 of the reservoir on the San Joaquin River? 20 MR. GROBER: No, it does not. 21 MR. GODWIN: What does it use, then, for inputs in the 22 tributaries? 23 MR. GROBER: That was the purpose of the collaborative 24 effort to drive the SJRIO model. When you are using it for 25 a certain level of development or certain level of CAPITOL REPORTERS (916) 923-5447 10804 1 discharges from the tributaries, it needs inputs something 2 such as DWRSIM, an operation model to come up with the 3 boundary conditions for the SJRIO model, what flows are in 4 the tributaries. 5 MR. GODWIN: DWRSIM provided the fixed inputs that you 6 used to do the SJRIO runs? 7 MR. GROBER: Yes, with some calibration to make the 8 discharges of the two models match for the base case. 9 MR. GODWIN: I was going to get to that in a little bit 10 here. 11 Let's say that you wanted to analyze a shift in the 12 timing of drainage discharges to the San Joaquin River. 13 That could, then, affect water quality at Vernalis, could it 14 not? 15 MR. GROBER: Yes. 16 MR. GODWIN: That could then require changes in New 17 Melones releases in order to achieve water quality; is that 18 right? 19 MR. GROBER: For meeting water quality if you had a 20 shift, yes, it would potentially need ideally, and as was 21 discussed in this meeting, to go through an iterative 22 process to converge upon a solution. 23 MR. GODWIN: SJRIO didn't affect the operation of New 24 Melones operations, right? 25 MR. GROBER: No. CAPITOL REPORTERS (916) 923-5447 10805 1 MR. GODWIN: It couldn't evaluate, for instance, if 2 there was sufficient water to provide those flows? 3 MR. GROBER: No. Correct, it could not. 4 C.O. STUBCHAER: That line of questioning, you didn't 5 do this, correct? And the answer was no. No means it is 6 not correct. So, it is not your fault, it is the 7 questioner. 8 MR. GODWIN: You can identify the potential for a 9 change in operations, but not necessarily evaluate those 10 changes? 11 MR. GROBER: That's correct. 12 MR. GODWIN: Ms. Kipps, let's go back to the analysis 13 that you performed. What did you do with the data that was 14 provided from Mr. Arora? 15 MS. KIPPS: The tributary inputs from DWRSIM I used to 16 input as flows near the mouth of the San Joaquin on the 17 Stanislaus, Tuolumne and Merced Rivers and the San Joaquin 18 River at Lander for the base case. 19 The table that has the additional flows or the 20 additional water required to meet the water quality -- water 21 flow objectives I used in various runs as water that could 22 be supplied from the Delta-Mendota Canal. And that data set 23 was added to the data set that represents the flows coming 24 in from, like, the Grasslands watershed area. 25 MR. GODWIN: On Page 3, the third paragraph, there is a CAPITOL REPORTERS (916) 923-5447 10806 1 description of the process used by you to -- 2 C.O. STUBCHAER: Is the Page 3 the reference to the 3 document -- 4 MR. GODWIN: Excuse me. Page 3 of SDWA Exhibit 12. 5 Thank you. 6 Page 3, in the third paragraph, describes how the SJRIO 7 and DWRSIM were calibrated. It is my understanding that 8 those two models have slightly different assumptions. So 9 that led to some differences in flows when comparing the two 10 models; is that correct? 11 MS. KIPPS: That is correct. 12 MR. GODWIN: After you provided the stream flow input 13 you had to make some adjustments in order to approximate the 14 Vernalis flows that were generated by DWRSIM; is that 15 correct? 16 MS. KIPPS: Yes. 17 MR. GODWIN: Then after you've made that adjustment, 18 you had your base study for the remainder of the runs; is 19 that correct? 20 MS. KIPPS: Yes. 21 MR. GODWIN: That base run, then, is identified on 22 Table 7 of SDWA 12? 23 MS. KIPPS: Yes. 24 MR. GODWIN: On the overhead is Table 7 from South 25 Delta Water Agency Exhibit 12. CAPITOL REPORTERS (916) 923-5447 10807 1 So let me go over this. The SJRIO base run would be 2 comparable to DWRSIM Study 468A; is that correct? 3 MS. KIPPS: Can you describe what you mean by 4 "comparable"? 5 MR. GODWIN: It's comparable in that it assumes that 6 water quality is met at Vernalis, but there is no additional 7 flow in the river to meet the flow objectives? 8 MS. KIPPS: Could you clarify in terms of water 9 quality, what you mean by water quality objectives being 10 met? 11 MR. GODWIN: I am referring to the Water Quality 12 Control Plan water quality objectives at Vernalis. 13 MS. KIPPS: So what was your question? 14 MR. GODWIN: The question was: This base run that was 15 generated using SJRIO, is this comparable to the DWRSIM 16 Study 468A in that your base run is meeting Vernalis water 17 quality, but not trying to meet any flow objectives? 18 MS. KIPPS: The base run indicated that water quality 19 objectives were not met in all months similar -- I mean, 20 compared to the DWRSIM run. So we used the flows from 21 DWRSIM and then we used SJRIO. SJRIO calculated the flows 22 at Vernalis and the salinity. Those values for salinity are 23 different. They are different models. They are -- not in 24 all months was the objective met for salinity. 25 MR. GODWIN: When you used the flow inputs from DWRSIM CAPITOL REPORTERS (916) 923-5447 10808 1 Study 468A and then ran that through the SJRIO, you got a 2 different water quality result at Vernalis than DWRSIM Study 3 468A? 4 MS. KIPPS: That's correct. 5 MR. GODWIN: And you attribute that in part to the 6 differences in the way the two models calculate water 7 quality? 8 MS. KIPPS: Yes, I do. 9 MR. GODWIN: Let's look at the Table 8 run, Exhibit 10 Number 12, SDWA Exhibit Number 12. And we have on the 11 overhead the first page from Table A. 12 Does this table show the simulated water quality at 13 Vernalis using the base run? 14 MS. KIPPS: Yes, it does. 15 MR. GODWIN: Earlier we had on the screen San Joaquin 16 River Group Exhibit 101, which showed the water quality at 17 Vernalis, and this was the result of modeling through the 18 DWRSIM 468A. We don't have enough room on the screen, but 19 if we compared Table 8 with Exhibit SJRGA 101 we would see 20 that the water quality is different? 21 MS. KIPPS: Yes, as would be expected. They are 22 different models. 23 C.O. STUBCHAER: Excuse me, are the units the same, 24 or is this siemens and the other one mhos? 25 MS. KIPPS: Interchangeable. They mean the same CAPITOL REPORTERS (916) 923-5447 10809 1 thing. 2 MR. GODWIN: Again, this is due to the way the two 3 models calibrate water quality; is that correct? 4 MS. KIPPS: How they calculate water quality. 5 MR. GODWIN: Calculate, excuse me. 6 Next I want to look at Table 9A from South Delta Water 7 Agency Exhibit 12. 8 Could you briefly describe what this table shows. 9 MS. KIPPS: What this table shows is that once we 10 generated the output from SJRIO, we calculated the flow and 11 salinity at Vernalis. And then, as post-processing, after 12 the model is run, we look at the salinity at Vernalis; and 13 if exceeds the flow, the objective, then we calculate how 14 much water of a certain quality that we have assumed that is 15 available from the Stanislaus River has to be added in order 16 to dilute the flow so that the salinity is below the 17 objective. This table indicates how much in terms of 18 thousand acre-feet on a monthly basis water of a certain 19 quality that we have assumed from Stanislaus would have to 20 be added in order to achieve salinity compliance at 21 Vernalis. 22 MR. GODWIN: Let's use 1922 as an example. Table 8 23 shows that in the month of August, the Vernalis electrical 24 conductivity was 867 microsiemens per centimeter; is that 25 right? CAPITOL REPORTERS (916) 923-5447 10810 1 MS. KIPPS: Yes. 2 MR. GODWIN: The standard during that particular month, 3 I believe, is 700 microsiemens per centimeter; is that 4 correct? 5 MS. KIPPS: That's right. 6 MR. GODWIN: So, looking at Table 9, then, in August of 7 1922, it would require an additional 33,000 acre-feet from 8 New Melones in order to bring the water quality objective 9 into compliance; is that right? 10 MS. KIPPS: I believe so, yes. 11 MR. GODWIN: Mr. Grober, Table 9A, this has a lot of 12 zeros on here and other places where there are not zeros. 13 This is indicating, then, in the months where there is not a 14 zero, that is indicating months when water quality was 15 exceeded? 16 MR. GROBER: Zeros indicate months where the water 17 quality objective was not exceeded, yes. 18 MR. GODWIN: Where there is a positive number, that is 19 indicating that that water quality objective was exceeded; 20 is that correct? 21 MR. GROBER: Yes. 22 MR. GODWIN: Well, the DWRSIM study showed that water 23 quality was met in all months, and this is showing that it 24 is not met. Why the difference? 25 MR. GROBER: As has been brought out by Joanne Kipps CAPITOL REPORTERS (916) 923-5447 10811 1 and Sushil Arora, they are two different models and they 2 calculate water quality differently. 3 MR. GODWIN: Does that mean that the DWRSIM results 4 that were provided to you were flawed? 5 MR. GORBER: I wouldn't use "flawed." As I heard the 6 testimony, they are two different models used for two 7 different purposes. DWRSIM, as I understand it, is an 8 operations model, covers very large area, as opposed to the 9 SJRIO, which is looking at much more detail of the San 10 Joaquin River. 11 MR. GODWIN: Would you say that one model more 12 accurately or more correctly models water quality than the 13 other model? 14 MR. GROBER: I would say that SJRIO models water 15 quality in greater detail. 16 MR. GODWIN: Let's look at Table 9A and Table 7 17 together. Is it correct that Table 7 summarizes the results 18 that are shown here on 9A for the base run? 19 MR. GROBER: I am sorry, could you repeat the 20 question? 21 MR. GODWIN: Table 7 summarizes the result of Table 9A 22 for the base run; is that correct? 23 MR. GROBER: Yes, that would be the base run. That's 24 correct. 25 MR. GODWIN: So, looking at Table 7, then, it CAPITOL REPORTERS (916) 923-5447 10812 1 summarizes the results for the months of March, April, May 2 and then a summary of three months or a summary of the three 3 months? 4 MR. GROBER: Yes. 5 MR. GODWIN: So, for example, looking at Table 9A, in 6 the month of March the average additional New Melones 7 releases in thousand acre-feet to meet the Vernalis salinity 8 objectives is 6,000 acre-feet; is that correct? 9 MR. GROBER: Yes, that is correct. 10 MR. GODWIN: And that shows up on Table 7 under March 11 average, 6,000 acre-feet, for the base run? 12 MR. GROBER: Yes. 13 MR. GODWIN: Then looking again at Table 9A, the 14 maximum additional New Melones releases in thousand 15 acre-feet to meet the Vernalis salinity objective is 46; is 16 that correct? 17 MR. GROBER: Yes, that is correct. 18 MR. GODWIN: And then that same number appears on Table 19 7 under the month of March? 20 MR. GROBER: Yes. 21 MR. GODWIN: And the percent exceed value represents, 22 then, the number of times over the 73-year period that 23 additional water is required for that particular month? 24 MR. GROBER: Yes. 25 MR. GODWIN: So, then, Table 7 for the base run CAPITOL REPORTERS (916) 923-5447 10813 1 displays only the information regarding the occurrences when 2 the SJRIO results indicate an exceedance of the water 3 quality objective; is that right? 4 MR. GROBER: It is showing results for all years. It 5 is a summary of results of the rate of exceedance. 6 MR. GODWIN: But Table 7 is just showing the result of 7 exceedances? 8 C.O. STUBCHAER: Mr. O'Laughlin. 9 MR. O'LAUGHLIN: Can we take our morning break sometime 10 soon? 11 C.O. STUBCHAER: I was going to ask Mr. Godwin how much 12 more he had to go. If he just has a couple more minutes, 13 there is no point in taking a break. 14 How much more? 15 MR. GODWIN: I have 15 more minutes. 16 C.O. STUBCHAER: Would it be all right if we take -- 17 MR. GODWIN: Yes. 18 C.O. STUBCHAER: Mr. Brown. 19 C.O. BROWN: This is very informative and interesting 20 and helpful. But it would be helpful to me in this rebuttal 21 if you could identify where this came up and what you're 22 rebutting. 23 MR. GODWIN: Okay. 24 C.O. BROWN: You don't have to do that now. When we 25 come back if you tie it in, it would be more beneficial. CAPITOL REPORTERS (916) 923-5447 10814 1 MEMBER FORSTER: I have another question. 2 C.O. STUBCHAER: Ms. Forster. 3 MEMBER FORSTER: The reason I want to ask my question, 4 because I can't remember them later when they are technical. 5 Can you put that back on, please? 6 I just heard something that confused me on the 7 exceedance. First I thought you said take the base run 8 under March, percent exceed. First I thought you explained 9 that the 29 percent meant that 29 percent of the time in the 10 73-year study period you needed more water. And then I 11 thought I heard in the next breath that 29 percent of the 12 time the objectives were exceeded. And that means two 13 different things to me. 14 Or is that the same thing? Is it because you needed 15 more water 29 percent of the time? Is that equals 29 16 percent of the time when objectives were exceeded, and, 17 therefore, you needed more water? Is that what you said? 18 MR. GROBER: I think that is what I said. It is the 19 same thing, really. When the objective -- every time the 20 objective is exceeded, more water is required. 21 MEMBER FORSTER: Okay. Thank you. 22 C.O. STUBCHAER: We will take our break. 23 (Break taken.) 24 C.O. STUBCHAER: Call the hearing back to order. 25 Mr. Godwin. CAPITOL REPORTERS (916) 923-5447 10815 1 MR. GODWIN: Just before we had left for the break, 2 the Board asked questions about what this was rebutting. 3 South Delta Water Agency had made numerous assertions 4 regarding the studies, how they were performed and what they 5 showed. 6 For instance, we had a table showing additional water. 7 Mr. Hildebrand wasn't sure if that was additional water to 8 meet flow objectives, to meet water quality objectives or to 9 meet both objectives. So we are establishing what that 10 table was used for. In addition, there were other 11 assertions made regarding the impacts on New Melones, the 12 savings for recirculation plan and so forth. 13 C.O. BROWN: Thank you. 14 MR. GODWIN: Mr. Steiner, could you put Table 9A back 15 up, please? 16 Before we get too much farther, I want to maybe 17 straighten some things out. This table is showing -- if I 18 am correct, this table is showing how much additional water 19 would be needed to meet the water quality objectives based 20 on the SJRIO base run; is that correct? 21 MR. GROBER: Yes. 22 MS. KIPPS: Yes. Of a certain quality that we have 23 assumed. 24 MR. GODWIN: Yes. 25 You can't compare this, for instance, with the table CAPITOL REPORTERS (916) 923-5447 10816 1 that was generated from the DWRSIM study; is that right? 2 MR. GROBER: It can certainly be compared. 3 MR. GODWIN: Well, you could compare them and look at 4 them. But because this is showing additional water is 5 needed to meet water quality objectives, these numbers are 6 going to be different than that table that we showed that 7 DWRSIM generated; is that right? 8 MR. GROBER: Yes, because of different methods used to 9 calculate water quality. 10 MR. GODWIN: So, in some instances DWRSIM might be 11 showing a violation of water quality and SJRIO might not 12 show a violation and vice versa? I haven't compared the 13 numbers, but that is possible, isn't it? 14 MR. GROBER: Yes. But it is not as simple as just a 15 random difference between the two. They tend to be 16 consistent in terms of when they are showing there is a 17 violation and water needs to be added, but they are 18 different in terms of magnitude. 19 MR. GODWIN: This may have been a better question: The 20 magnitude of differences between SJRIO and DWRSIM would be 21 different and that is in large part because of two models 22 are calculating water quality differently? 23 MR. GROBER: Yes. 24 MR. GODWIN: Let's go back to Table 7, please. 25 And looking at the box labeled "Base Run," under the CAPITOL REPORTERS (916) 923-5447 10817 1 value percent exceedance, this is showing the occurrences 2 when -- actually looking at the whole box, the average 3 maximum sum and percent exceedance, this is displaying the 4 occurrences when SJRIO results indicate an exceedance of 5 water quality objectives; is that right? 6 MS. KIPPS: Yes. 7 MR. GODWIN: And those exceedances are the result of 8 the modeling differences between DWRSIM and SJRIO? 9 MS. KIPPS: Yes. 10 MR. GODWIN: Then, these exceedances were then used as 11 a benchmark to compare the other model; is that right? 12 MS. KIPPS: That's right. 13 MR. GODWIN: And your analysis used the exceedances as 14 a comparative, on a comparative basis; is that right? 15 MS. KIPPS: Well, we looked at if we changed input, an 16 input to the model, and then came up with different numbers 17 in terms of percent exceedance, then we look at differences 18 as well as the amount of water that would be needed to 19 dilute the flow. 20 MR. GODWIN: In your model or these runs only looked at 21 exceedances on a comparative basis; they didn't look at -- 22 for instance, they didn't look at improvements or 23 impairments to water quality during a month when water 24 quality wasn't obtained? 25 MS. KIPPS: Could you rephrase that? CAPITOL REPORTERS (916) 923-5447 10818 1 MR. GODWIN: Let's say there was a month where, just 2 any run, let's say run number two, let's say you ran the 3 model and it resulted in worst water quality but the same 4 number of exceedances. That wouldn't show on your 5 comparison; is that right? 6 MS. KIPPS: Not in this table, not -- no. 7 MR. GODWIN: So, you only looked at exceedances of 8 water quality and not improvements or impairments that were 9 still within the water quality? 10 MS. KIPPS: I did, but it is not indicated, perhaps, in 11 the report. I was particularly interested in how water 12 quality upstream from Vernalis change as a result of these 13 things. So, but -- 14 MR. GODWIN: It is not showing here on Table 7? 15 MS. KIPPS: No. This is a summary. 16 If a result had the same percentage of months in 17 exceedance, there yet, nevertheless, may be a difference in 18 the amount of water from New Melones required to dilute 19 because it may have improved the situation somewhat, but not 20 enough to make it in compliance. So you may have a 21 situation where you have the same number of months in 22 exceedance, but you may have less water required from New 23 Melones in order to achieve compliance. 24 MR. GODWIN: We could have months -- comparing runs to 25 the base run, we could have a month where the percent CAPITOL REPORTERS (916) 923-5447 10819 1 exceedance is the same but the amount of water from New 2 Melones would be different? 3 MS. KIPPS: Yes. 4 MR. GODWIN: By doing that then we could compare the 5 differences between the two runs in terms of what they 6 needed from New Melones to meet the water quality 7 objectives? 8 MS. KIPPS: That's right. 9 MR. GODWIN: I would like to move on to some of the 10 comparable studies that you performed. 11 As I understand, these other runs outside of the base 12 run involved combining the effect of both recirculation and 13 adjustments to drainage or wetland discharges and different 14 combinations of those two? 15 MS. KIPPS: That's right. 16 MR. GODWIN: Let's look at run number five, first of 17 all. My understanding of run number five was that this run 18 was to illustrate the effect to water quality from using 19 recirculation to meet the flow objectives at Vernalis; is 20 that right? 21 MEMBER FORSTER: Can I have that over a little -- 22 MS. KIPPS: Repeat the question. 23 MR. GODWIN: My understanding of run number five is 24 that this run was run to look at the effects of 25 recirculation on water quality. And whenI say recirculation CAPITOL REPORTERS (916) 923-5447 10820 1 I am referring to you tried to use recirculation to meet the 2 flow objectives for the Water Quality Control Plan for the 3 entire year. 4 MS. KIPPS: That was the objective of run five. 5 However, in preparing for this testimony I discovered that 6 the results indicated for this is actually from another run, 7 run six, which is the same as run five in that the table of 8 the additional water needed to meet the flow objectives that 9 we were provided from DWR, we only did recirculation in 10 months in which Vernalis was already in compliance with the 11 salinity objective, because we wanted to see whether the 12 recirculation made matters worse. So run five, here, is 13 actually the summary of run six, which only did 14 recirculation when Vernalis was in compliance. And as you 15 can see, there is no difference between this and base 16 case. 17 I might also add that in some of the summary columns 18 here there was a spreadsheet. The sums may not add up. In 19 case you are scratching your head and wondering why it 20 didn't add up, this is another thing that I learned in 21 preparing for this testimony. But that is, run five is 22 actually run six. 23 MR. GODWIN: Well, I am going to stick with run five 24 because it says run five up there. 25 MS. KIPPS: Yes. CAPITOL REPORTERS (916) 923-5447 10821 1 MR. GODWIN: Run five, then, you used recirculation to 2 meet the flow objectives in those months when the flow 3 objective was not being met? 4 MS. KIPPS: Could you rephrase that? Could you repeat 5 that? 6 MR. GODWIN: Yes. In run five you used DM 7 recirculation in order to meet the May 1995 Water Quality 8 Control Plan flow objectives at Vernalis in those months 9 when the flow objective was not being met? 10 MS. KIPPS: When the salinity objective was met we -- 11 if there was a value in the additional water to be added for 12 the flow objective, we added that as DMC recirculation. If 13 Vernalis was in exceedance of its salinity objective, we 14 didn't add recirculation. 15 MR. GODWIN: So there could have been a month where 16 water quality was exceeded and the flow objective was not 17 being met and you didn't put any additional water in? 18 MS. KIPPS: That's right, yeah. 19 MR. GODWIN: So this run, then, just ran DMC 20 recirculation to meet the flow objectives in months when 21 water quality was being met? 22 MS. KIPPS: That's right. 23 C.O. STUBCHAER: I have a question, Mr. Godwin, on 24 that. 25 Was that when the water quality at Vernalis was being CAPITOL REPORTERS (916) 923-5447 10822 1 met without the additional, any recirculated water? 2 MS. KIPPS: Yes. 3 C.O. STUBCHAER: Did the addition of recirculated water 4 change the water quality at Vernalis, or did you try to 5 determine that? 6 MS. KIPPS: Yes, it did. Generally it reduced the 7 salinity of Vernalis. 8 MR. GROBER: Just for clarification. For the true run 9 five it improved the salinity at Vernalis as opposed to what 10 seems to be here, which seems to be no effect as run five. 11 It was neutral. Which, again, just to reiterate, this -- 12 what is shown here is run five is actually the results of 13 run six. So what this is showing is that recirculation 14 water being added only when Vernalis objectives are being 15 met, and on that run the water quality effects were neutral 16 compared to the base run. And for what should have been in 17 here as run five there would have been some improvement. 18 MR. GODWIN: I am just going to ask you one question. 19 Though this went out, this is a preliminary draft report; is 20 that right? 21 MS. KIPPS: That's right. 22 MR. GODWIN: It was never finalized; is that right? 23 MS. KIPPS: That's correct. 24 MR. GODWIN: Run number five or six did not use any 25 tile drainage or wetland discharge reoperation; is that CAPITOL REPORTERS (916) 923-5447 10823 1 right? 2 MS. KIPPS: That's right. 3 MR. GODWIN: It only used recirculation, DMC 4 recirculation? 5 MS. KIPPS: Yes. 6 MR. GODWIN: Were there any other studies that isolated 7 the recirculation, DMC recirculation, from the action of 8 tile drainage or wetland discharge reoperation? In other 9 words, any runs that looked solely at recirculation. 10 MS. KIPPS: Yes. Run one and -- we did some other runs 11 that explored the split month scheduling of pulse flows. 12 MR. GODWIN: Run one just looked at the April/May pulse 13 flow period; is that correct? 14 MS. KIPPS: That's correct. 15 MR. GODWIN: They didn't try to meet the other flow 16 objectives during the other times of the year? 17 MS. KIPPS: That's right. 18 MR. GODWIN: I think you probably talked about this, 19 but I want to go over it, the assumptions used for the 20 location and the quality of run number five. Where did you 21 input the water into the system for run number five? 22 MS. KIPPS: It was input as part of the drainage from 23 the Grasslands watershed that -- because it is coming in 24 from the Newman Wasteway, it's in that vicinity. So we had 25 many components of the drainage from the Grasslands CAPITOL REPORTERS (916) 923-5447 10824 1 watershed: wetland releases, tile drainage, agricultural 2 return flows. So, this was yet another component that we 3 added to that drainage. 4 MR. GODWIN: So it was a location that was just assumed 5 to be the Newman Wasteway? 6 MR. GROBER: Yes. It was a model simplification 7 because it is within a couple of river miles and upstream of 8 the Merced River. 9 MR. GODWIN: What water quality did you use for that 10 recirculation water? 11 MS. KIPPS: I used various values, according to the 12 water year type. Because based on historical data, it seems 13 when the water year is on the dry side the salinity in the 14 Delta is higher. If it is a wet year, the salinity of the 15 Delta is lower. So during the wet years, I used 225 16 milligrams per liter. And for normal, above normal and 17 below normal I used 255 milligrams per liter. And in dry 18 and critically dry years I used 300 milligrams per liter. 19 That was the quality that assigned the DMC water. 20 MR. GODWIN: In other words, you used water that was 21 assumed to be indicative of Delta-Mendota Canal water? 22 MS. KIPPS: Yes. 23 MR. GODWIN: After running -- for instance, after 24 running run five, you then compared the results to the base 25 run; is that right? CAPITOL REPORTERS (916) 923-5447 10825 1 MS. KIPPS: Yes. 2 MR. GODWIN: For purposes of comparison you would 3 compare the box, your label is, run five on Table 7 with the 4 box labeled base run and the differences between the two 5 runs show up as differences in additional water from New 6 Melones and percent exceedances of the water quality 7 objective; is that right? 8 MS. KIPPS: The differences aren't indicated here, but 9 you can -- this is the output, the summary of the output. 10 MR. GODWIN: The individual differences aren't here, 11 but the summary is. 12 This shows there is no differences, then, in March, 13 April or May; is that correct? 14 MS. KIPPS: For this run, which actually was run six 15 and not five. 16 MR. GODWIN: So based on this analysis, could you 17 conclude then that recirculation alone would not benefit 18 water quality? 19 MS. KIPPS: I would say that it would not result in 20 Vernalis being more in noncompliance with the salinity 21 objective. 22 MR. GODWIN: Let's look at run number 16. As I 23 understand run 16, this was a run that looked at meeting the 24 April/May pulse flow requirements combined with tile 25 drainage reoperation? CAPITOL REPORTERS (916) 923-5447 10826 1 MS. KIPPS: That's right. 2 MR. GODWIN: And the tile drainage reoperation 3 consisted of withholding a portion of the tile drainage in 4 March and April and releasing in May? 5 MS. KIPPS: Yes. Only in years where there was 6 recirculation. 7 MR. GODWIN: So run 16 did not attempt to meet any 8 other Water Quality Control Plan flow objectives besides the 9 April/May pulse flow? 10 MS. KIPPS: That's right. 11 MR. GODWIN: Looking at the tile drainage reoperation, 12 what run 16 does is shift some of the tile drainage from 13 March and April into May; is that right? 14 MS. KIPPS: Yes. 15 MR. GODWIN: Looking at Table 7 in the box labeled run 16 16, we see that as a result of that, it would appear that 17 the percent exceedances for March and April declines as 18 compared to the base case, but for the month of May the 19 percent exceedance increases; is that correct? 20 MS. KIPPS: That's correct. 21 MR. GODWIN: So would it be safe to say that April and 22 March the water quality was improved under run 16, but in 23 May it was made worse? 24 MS. KIPPS: It appears so. 25 MR. GODWIN: Did you perform any studies that looked CAPITOL REPORTERS (916) 923-5447 10827 1 only at tile drainage reoperation and wetland restart of the 2 operation with no recirculation? 3 MS. KIPPS: Not in this study. 4 MR. GODWIN: Would you say, based on the study that you 5 performed here, that drainage and wetland discharge 6 management would show improvements to water quality as 7 compared to the base run, even without recirculation? 8 MS. KIPPS: I can't say. 9 MR. GODWIN: I need to clarify a conclusion on Page 9 10 of your report, Page 9 of South Delta Water Agency Exhibit 11 12. 12 Looking at the last paragraph, the second sentence 13 reads: 14 If DMC recirculation can be employed for all 15 or some of this add water, then what flows 16 that would have been supplied by east side 17 tributaries for this purpose can be saved for 18 other uses. (Reading.) 19 Where if anywhere in this analysis did you evaluate the 20 provision of flows for water quality plan flow objectives 21 through releases from the east side tributaries? 22 MS. KIPPS: Could you repeat that? 23 MR. GODWIN: In this report you did an evaluation 24 trying to meet the Vernalis flow objective with releases, 25 additional releases, from the east side tributaries? CAPITOL REPORTERS (916) 923-5447 10828 1 MS. KIPPS: No. That was not part of the study. 2 MR. GODWIN: Did you perform any analysis to determine 3 whether or not water was available from the east side 4 tributaries in order to meet the flow objectives? 5 MS. KIPPS: That was not part of the study. 6 MR. GODWIN: Without knowing what the State Water 7 Resources Control Board may require from the east side 8 tributaries in order to meet the Water Quality Control Plan 9 flow objectives from the east side tributaries, you can't 10 really say for certain whether or not there would be any 11 water savings; is that right? 12 MS. KIPPS: What I meant here is that I believed in 13 making these conclusions that the flow objective would have 14 been met by releases from east side tributaries or would 15 have been attempted to have been met by east side tributary 16 releases. With the recirculation of Delta water serving 17 that purpose, then my assumed use of east side tributaries 18 for that purpose it seems like it would free up that water 19 that would have been used for making up the flow objective 20 and conceivably been used for other purposes. 21 MR. GODWIN: So, then, absent the assumption that water 22 would come from east side tributaries, absent that 23 assumption, there would be no saving; is that correct? 24 MS. KIPPS: No savings from? 25 MR. GODWIN: No water savings from recirculation. CAPITOL REPORTERS (916) 923-5447 10829 1 MS. KIPPS: Could you rephrase that? 2 MR. GODWIN: Absent your assumption that water would be 3 provided from the east side tributaries, you can't conclude, 4 then, that there would be any savings from recirculation; is 5 that correct? 6 MS. SENITTE: Clarification, savings by the east side 7 tributaries? 8 MR. GODWIN: Yes. 9 MS. KIPPS: As I understand it, if the water wasn't 10 used, if the water didn't come from east side tributaries 11 for this purpose, then, no, there would not be any savings. 12 MR. GODWIN: I guess I could ask that another way. The 13 east side tributaries aren't providing any water right now? 14 MS. KIPPS: I don't know. 15 MR. GODWIN: If we adopted recirculation, there would 16 be no net change in the operations of the east side 17 tributaries? 18 MS. KIPPS: I can't answer that. 19 MR. GODWIN: In performing the studies that you did for 20 this report, what was your assumption regarding the 21 availability of pumping capacity to accommodate the 22 additional water provided through the DMC recirculation? 23 MS. KIPPS: As I recollect, the only limiting factor 24 that we had was the capacity of the Newman Wasteway and 25 whether the Newman Wasteway was large enough to accommodate CAPITOL REPORTERS (916) 923-5447 10830 1 the add water, and we assumed that all the add water could 2 be provided by project pumps. 3 MR. GODWIN: Outside the assumption that the water 4 could be there, you made no independent evaluation whether 5 the water could, in fact, be made available? 6 MS. KIPPS: I remember that being a point of discussion 7 at a meeting we had with the Bureau of Reclamation and DWR. 8 And as I recollect, I don't think that was -- I didn't cover 9 it. I left that to the federal and state modelers, their 10 project. 11 MR. GODWIN: Your study did not perform any analysis to 12 determine the viability of or the impacts of providing water 13 through DMC recirculation? 14 MS. KIPPS: Could you repeat that? 15 MR. GODWIN: Your study didn't provide any independent 16 analysis of the impacts of DMC recirculation; is that right? 17 MS. KIPPS: What do you mean by "independent"? 18 MR. GODWIN: You didn't look at -- for instance, you 19 didn't evaluate the impact of DMC recirculation on third 20 parties, for instance, west side CVP contractors? 21 MS. KIPPS: This is simply a water quality flow 22 modeling exercise. 23 MR. GODWIN: I have no more questions. 24 C.O. STUBCHAER: Thank you, Mr. Godwin. 25 Who wishes to cross-examine this panel? CAPITOL REPORTERS (916) 923-5447 10831 1 Mr. O'Laughlin, Mr. Herrick, Mr. Jackson. 2 Anyone else? 3 You are right, Mr. Herrick. Followed by Mr. Jackson, 4 followed by Mr. O'Laughlin. 5 ---oOo--- 6 CROSS-EXAMINATION OF 7 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 8 BY SOUTH DELTA WATER AGENCY 9 BY MR. HERRICK 10 MR. HERRICK: Thank you, Mr. Chairman. John Herrick 11 for South Delta Water Agency. 12 Just a few clarifying questions. Sorry to take up too 13 much of your time. 14 The direct examination went through various charts and 15 graphs and everything contained in the report. 16 Ms. Kipps, is there anything that has happened that 17 makes you change your conclusion that you put forth on Page 18 9 of South Delta Number 12? 19 MS. SENITTE: What do you mean by that? 20 MR. HERRICK: Do you still agree with your conclusion 21 that you put on Page 9 of your report? 22 MS. KIPPS: Could you be more specific as to what 23 conclusion you are referring to? 24 MR. HERRICK: The bottom of Page 9 says: 25 In conclusion, the add water required to meet CAPITOL REPORTERS (916) 923-5447 10832 1 the May '95 Water Quality Control Plan Delta 2 standards that could be supplied by DMC 3 recirculation ranges from 3,000 acre-feet in 4 wet years to over a hundred thousand 5 acre-feet in normal water years. (Reading.) 6 Is that your conclusion? 7 MS. KIPPS: That is correct. 8 MR. HERRICK: And if that water had then -- if water 9 for meeting those standards, the 1995 Water Quality Control 10 Plan standards, was in the absence of recirculation supplied 11 by the east side tributaries, then there would be that same 12 amount of savings from the tributaries; is that correct? 13 MS. KIPPS: If the water were supplied my east side 14 tributaries, then that would be true. 15 MR. HERRICK: If they were being supplied some other 16 way, that other way would have benefited from this 300 to a 17 thousand acre-feet amount, correct? 18 MS. KIPPS: Yes. 19 MR. HERRICK: Then your next conclusion is that 20 modeling study demonstrated that DMC recirculation during 21 the spring pulse flow results in slightly improved water 22 quality conditions at Vernalis, and, consequently, less 23 release is required from New Melones. Is that your 24 conclusion from the modeling you've done? 25 MS. KIPPS: Yes, that's correct. CAPITOL REPORTERS (916) 923-5447 10833 1 MR. HERRICK: The next one is at Crows Landing, the DMC 2 recirculation is substantially improved, and I don't mean to 3 paraphrase too much. 4 Is that one of your conclusions from your modeling? 5 MS. KIPPS: Yes. Really improved conditions along the 6 main stem. 7 MR. HERRICK: That is because there is recirculation 8 water being added to the water farther upstream? 9 MS. KIPPS: That's right. 10 MR. HERRICK: So, it is providing some sort of dilution 11 farther upstream? 12 MS. KIPPS: A lot of dilution. 13 MR. HERRICK: And then, your final conclusion says: 14 Even greater improvements in water quality 15 conditions result from commingling DMC 16 recirculation with the tile drainage 17 operation. (Reading.) 18 That was one of your conclusions from modeling; is that 19 correct? 20 MS. KIPPS: Yes. 21 MR. HERRICK: The fact that the DWRSIM model may show 22 different salinity numbers than the SJRIO amount, that 23 doesn't change your conclusions from this report, does it? 24 MS. KIPPS: No. 25 MR. HERRICK: In fact, it said you expected those CAPITOL REPORTERS (916) 923-5447 10834 1 differences to occur, right? 2 MS. KIPPS: Yes. 3 MR. HERRICK: The purpose of the DWRSIM model was to 4 develop input data for your SJRIO model? 5 MS. KIPPS: Yes, flow data. 6 MR. HERRICK: The whole purpose of that was to analyze 7 what potential effects there may be if you add recirculation 8 and then also if you add tile drainage reoperation? 9 MS. KIPPS: And wetland reoperation. 10 MR. HERRICK: Then you did a whole bunch of different 11 runs which did 50 percent, a hundred percent, with or 12 without recirculation; is that correct? 13 MS. KIPPS: Whenever we did reoperation, we always did 14 recirculation. 15 MR. HERRICK: I thought there was a run that didn't, 16 but that is all right. 17 Now on Table 7 of SDWA 12, I don't think you were here, 18 but basically Alex Hildebrand compared the base run with run 19 16. And is that the comparison that you used in developing 20 your conclusions for this, in the text part of your report? 21 MS. KIPPS: I believe so. 22 MR. HERRICK: In other words, there were other runs 23 done, but the proposal, as you understood it, was to see 24 what would happen if DMC recirculation was combined with 50 25 percent drainage reoperation? CAPITOL REPORTERS (916) 923-5447 10835 1 MS. KIPPS: Yes. We discovered as result of this 2 exercise that the best benefit that you can achieve was to 3 do DMC recirculation and then to do tile drainage 4 reoperation in years in which you do have DMC recirculation, 5 and that is run 16. And that showed that you get 6 improvement in the water quality at Vernalis, the greatest 7 improvement in water quality at Vernalis. 8 MR. HERRICK: In the discussions that led to the work 9 on these runs, I believe you mentioned that there were 10 members from other groups participating, rather than just 11 you and perhaps Alex Hildebrand; is that correct? 12 MS. KIPPS: That's correct. 13 MR. HERRICK: Could you briefly tells us what other 14 modelers may have been involved, not just modelers, other 15 people may have been involved in those discussions as best 16 you recall? 17 MR. GROBER: K.T. Shum, Contra Costa Water District, I 18 believed was involved. Some staff from the Bureau of 19 Reclamation. I believe Peggy Manza was involved. Francis 20 Chung, of course, and several of his staff. 21 MR. HERRICK: So, basically, there were representatives 22 of the Bureau, DWR, Regional Board, Contra Costa Water 23 District. 24 Did Dr. Orlob also participate? 25 MR. GROBER: Yes. CAPITOL REPORTERS (916) 923-5447 10836 1 MR. HERRICK: So, Alex and Dr. Orlob from South 2 Delta. I believe the last witness mentioned discussions 3 with modelers with the State Board. Was that part of your 4 group or was that prior to your participation? 5 MR. GROBER: I think there was some involvement early 6 on that might have involved the State Board. 7 MR. HERRICK: You guys didn't craft it so it was 8 somehow misleading? It was open to discussion to determine 9 agreeable parameters and input for this process; isn't that 10 what happened? 11 MR. GROBER: The fact that is why you see 18 runs here. 12 It is going through many permutations and sees what falls 13 out. 14 MR. HERRICK: Now, going back to Table 7 again, the 15 table shows information for months of March, April and 16 May. Are those months shown because those are the months 17 either drainage reoperation or recirculation occurs? 18 MS. KIPPS: That's right. The focus of this study was 19 to look at spring pulse flow and how recirculation, tile 20 drainage, reoperation and/or wetland reoperation would 21 affect the base case. And since we are only looking at the 22 spring pulse flow, those are the only months germane to the 23 study. 24 MR. HERRICK: So, even if there are other water quality 25 or water flow requirements in other months, that was not the CAPITOL REPORTERS (916) 923-5447 10837 1 focus of this analysis; is that correct? 2 MS. KIPPS: That's right. 3 MR. HERRICK: There was some confusion, I think, about 4 the potential or the differences that may exist between the 5 two different models run. Would you agree with the 6 statement that the information in your report should not be 7 used to necessarily predict specific numbers, but to show a 8 change in direction resulting from certain actions? 9 MS. KIPPS: Yes. That is the typical use of these 10 computer models, not to just try to forecast, unless you're 11 calculating. But usually it is a tool to see how things 12 change if you are changing the situation. 13 MR. HERRICK: So, it is not your testimony, then, that 14 the Board or anybody else should use these model runs to 15 determine whether or not in April of 1952 there was a 16 correct prediction of the TDS? 17 MS. KIPPS: That's true. 18 MR. HERRICK: That is not the purpose? 19 MS. KIPPS: That is not the purpose. 20 MR. HERRICK: I believe you just did say that 21 periodically these models are recalibrated in order to make 22 sure that there is not some new change that might be 23 throwing off the results; is that correct? 24 MS. KIPPS: I can't speak to the future of these 25 models. CAPITOL REPORTERS (916) 923-5447 10838 1 MR. HERRICK: Now, again on Table 7, the base run which 2 is the upper left-hand corner chart, basically these are the 3 numbers that are also in your text of your report; is that 4 correct, in the comparison of the results of the model 5 runs? 6 MS. KIPPS: I would have to confirm that. 7 MR. HERRICK: Let's just look at March. So, according 8 to the base run -- 9 C.O. STUBCHAER: March of what year? 10 C.O. BROWN: Referring to the report? 11 MR. HERRICK: I am on Table 7. 12 C.O. STUBCHAER: You were talking about what was in the 13 text versus what was in the table, I thought. 14 MR. HERRICK: I asked her if the information in the 15 base run on the table was the information that she describes 16 in the text of the report. 17 C.O. STUBCHAER: So where in the text were you 18 referring to? 19 MR. HERRICK: That is part of the conclusions of the 20 savings. Let me just start over if there was confusion. I 21 apologize. 22 Let's just go to Table 7 in the base run. That shows 23 that the maximum amount needed in March in order to meet 24 water quality at Vernalis is 46,000 acre-feet; is that 25 correct? CAPITOL REPORTERS (916) 923-5447 10839 1 MS. KIPPS: That's right. 2 MR. HERRICK: Then, if you go over to run 16, it shows 3 that the maximum amount needed when you do recirculation 4 with a 50 percent of withholding of tile drainage is only 5 32,000; is that correct? 6 MS. KIPPS: That's correct. 7 MR. HERRICK: And then you can do the same thing for 8 the sum for the March column and compare that with the sum 9 of the run 16; is that correct? 10 MS. KIPPS: Yes. 11 MR. HERRICK: Then, the final line of those two charts 12 is the percent exceedance, which shows that there is a 10 13 percent less exceedance, I will say, that is describing it, 14 10 percent less exceedance when you do the recirculation 15 with the withholding of drainage; is that correct? 16 C.O. STUBCHAER: Which month? 17 MR. HERRICK: In March. 18 C.O. STUBCHAER: Slide it over so we can see May. 19 MR. GROBER: I was just discussing a point of 20 clarification. That you can certainly compare the average 21 values directly. But comparing the maximums, care must be 22 taken because that is the maximum within the full time 23 period. It is not necessarily a one-to-one correlation 24 between the maximums. 25 MR. HERRICK: Certainly. CAPITOL REPORTERS (916) 923-5447 10840 1 Don't get me wrong, Mr. Grober. You can join in any of 2 these answers. I don't mean to end up asking all -- 3 C.O. STUBCHAER: If it is not clear, both members of 4 the panel may consult and answer jointly, whoever has the 5 best, most information. 6 You didn't get an answer to your question on the 10 7 percent. I don't think you did, Mr. Herrick. 8 MR. GROBER: There is a 10 percent difference in the 9 rate of exceedance between the two and it is improvement in 10 run 16. 11 MR. HERRICK: We shouldn't take that, again, as a hard 12 and fast number of what would occur, but rather a 13 directional improvement in the number of exceedances that 14 would occur. Is that a fair way to state that? 15 MR. GROBER: Yes, exactly. It is only a difference. 16 MR. HERRICK: If we change the various inputs, that 17 number might change; is that correct? 18 MR. GROBER: Yes. 19 MR. HERRICK: Was one of the assumptions in this 20 modeling that any barriers would be installed in the South 21 Delta? 22 MR. GROBER: I don't recall, exactly. I believe there 23 was some discussion on that, but I couldn't testify about 24 the details. 25 MR. HERRICK: That's okay. I won't pursue that. CAPITOL REPORTERS (916) 923-5447 10841 1 Let's go to Table 9A, which was discussed in the 2 direct. Again, would you agree that it would not be 3 productive to compare the numbers on Table 9A with any of 4 the specific information generated by DWRSIM? 5 MS. KIPPS: Could you rephrase that? 6 MR. HERRICK: Table 9A shows us the additional water 7 from New Melones in order to meet the salinity objective; is 8 that correct? 9 MS. KIPPS: Yes. 10 MR. HERRICK: That is based on input that was put into 11 the model, correct? 12 MS. KIPPS: Yes. 13 MR. HERRICK: Do you expect the amounts required under 14 Table 9A would match any amounts that might be assumed or 15 required in running DWRSIM? 16 MR. GROBER: No, because these were in the base 17 results for DWRSIM. There was already water being released 18 to meet water quality. This is showing additional water 19 that would need to be released based on the differences in 20 the way the model calculated water quality. 21 MR. HERRICK: The final question is: Do you think the 22 results of your analysis contained in this report has 23 value? 24 MR. GROBER: Yes. 25 MR. HERRICK: Could you describe what that value is? CAPITOL REPORTERS (916) 923-5447 10842 1 MR. GROBER: The value is looking at a fairly simple 2 set of assumptions, even though it might seem quite 3 complicated because of lots of documentation from various 4 scenarios, but showing ultimately that two things can be 5 achieved through recirculation of DMC water. 6 Flow objectives can be achieved at the same time that 7 water quality objectives are not negatively impacted, and, 8 in fact, water quality objectives can be met with somewhat 9 greater frequency in association with the tile drainage. 10 MR. HERRICK: Of course, we don't know what any savings 11 -- what any saved water could be used for that may be -- let 12 me start over. 13 If the recirculation provides this 3- to a hundred 14 thousand acre-feet of water in any particular year, then 15 that water that is not provided from some other source could 16 be available for other uses; is that correct? 17 MR. GROBER: Yes. 18 MR. HERRICK: No further questions. 19 C.O. STUBCHAER: Mr. Herrick. 20 Mr. Jackson. 21 ---oOo--- 22 // 23 // 24 // 25 // CAPITOL REPORTERS (916) 923-5447 10843 1 CROSS-EXAMINATION OF 2 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 3 BY REGIONAL COUNCIL OF RURAL COUNTIES 4 BY MR. JACKSON 5 MR. JACKSON: Michael Jackson representing the 6 Regional Council of Rural Counties. 7 I just have -- I want to go back over the conclusions 8 of the study. You have indicated in response to Mr. 9 Herrick's questions that water quality can be met by 10 recirculation at Vernalis, correct? 11 MS. KIPPS: I believe it was the flow objective. 12 MR. JACKSON: Can be met at Vernalis by recirculation? 13 MS. KIPPS: Under the assumptions that we used in the 14 study. 15 MR. JACKSON: And in doing so, the study showed a 16 substantial improvement upstream on the San Joaquin that 17 would not be present from water releases from New Melones? 18 MS. KIPPS: That's right. 19 MR. JACKSON: Thank you. 20 C.O. STUBCHAER: Mr. O'Laughlin. 21 ---oOo--- 22 // 23 // 24 // 25 // CAPITOL REPORTERS (916) 923-5447 10844 1 CROSS-EXAMINATION OF 2 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 3 BY OAKDALE IRRIGATION DISTRICT 4 BY MR. O'LAUGHLIN 5 MR. O'LAUGHLIN: Good morning. I am Tim O'Laughlin. 6 I represent Oakdale Irrigation District. 7 Turn to SJRIO Table Number 5, South Delta Water Agency 8 Exhibit Number 12. 9 Could you put up SJRGA 102? 10 Why don't you slide it down to the bottom. Let's look 11 at 1993, real quick. Thank you. 12 Now, Ms. Kipps, is it true to say that the average DMC 13 recirculation input expressed on Table Number 5 solely comes 14 from the table provided to you by DWR which is shown on 15 Exhibit 102? 16 MS. KIPPS: Repeat the question. 17 MR. O'LAUGHLIN: In other words, in order to arrive at 18 values set forth under average DMC recirculation input, 19 thousand acre-feet, under Table Number 5 for a wet year, 20 let's take a wet for example, you used the numbers assigned 21 to wet years from the DWR Run 468A which is shown under 22 SJRGA 102? 23 MS. KIPPS: Yes. I calculated averages based on their 24 water year type. 25 MR. O'LAUGHLIN: When you did that, you only looked at CAPITOL REPORTERS (916) 923-5447 10845 1 the months of April and May; is that correct? 2 MS. KIPPS: I believe so. 3 MR. O'LAUGHLIN: That is what Table Five says; it says 4 April to May on the top. 5 Did you look at any other months? 6 MS. KIPPS: Well, for this report I focused on April 7 and May. Of course, the modeling study I did look at other 8 months as well. 9 MR. O'LAUGHLIN: In 1993 I will represent to you was a 10 wet year. In the April/May under the amounts provided there 11 would be -- very hard to read this stuff -- 165,000 12 acre-feet supplied in April and in May there would be 85,000 13 acre-feet. So, roughly about 250,000 acre-feet of water? 14 MS. KIPPS: In 1993. 15 MR. O'LAUGHLIN: Right. Do averages really mean 16 anything? Because if we looked on Table Number 5, you have 17 a wet year, and in April and May you are averaging 14,000 18 and 22,000 and your total average is 37,000. But that would 19 be entirely different in 1993 if you had to recirculate 258 20 compared to 37,000 acre-feet of water; is that correct? 21 MS. KIPPS: Shows that there is a wide change. 22 MR. O'LAUGHLIN: That would be true for normal years as 23 well; is that correct? In other words, the average is 105. 24 So I am going to assume there are numbers that are higher 25 than 105 for normal years; would that be correct? CAPITOL REPORTERS (916) 923-5447 10846 1 MS. KIPPS: That would be a safe assumption. 2 MR. O'LAUGHLIN: In fact, if we wanted to look at what 3 the real numbers would be on a yearly basis, we would only 4 have to look at the DWRSIM output that is expressed in SJRGA 5 Exhibit 102; is that correct? 6 MR. GROBER: Yes. 7 MR. O'LAUGHLIN: Thank you. 8 Now, one of the things I heard was you looked at Newman 9 Wasteway; is that correct? Did you look at the carrying 10 capacity of Newman Wasteway? 11 MS. KIPPS: As I stated before, the capacity of Newman 12 Wasteway was one of the limited factors as to how much water 13 we could recirculate. 14 MR. O'LAUGHLIN: Do you know how it was limited, to 15 what amount? 16 MS. KIPPS: I believe it was on the order of 3,300 cfs. 17 I'd have to refer to the report. 18 MR. O'LAUGHLIN: If we just heard from -- and you were 19 in the room when Mr. Sushil Arora testified; is that correct? 20 MS. KIPPS: I was here. 21 MR. O'LAUGHLIN: You understood when he said in 1993, 22 in April, he said that most of that water, in response to a 23 question by Board Member Brown, would have to come back 24 down in the last 15 days of April and not in the entire 30 25 days of April; is that correct? CAPITOL REPORTERS (916) 923-5447 10847 1 MS. KIPPS: That's correct. 2 MR. O'LAUGHLIN: Have you done a calculation to go back 3 and assume that if you have 15 days, whether or not you 4 could send 165,000 acre-feet of water down to the Newman 5 Wasteway? You can't, can you? Do you know how to convert 6 cfs into acre-feet, Ms. Kipps? 7 MS. KIPPS: Yes. 8 MR. O'LAUGHLIN: Let's just use ballpark numbers; they 9 are easier. 3,300 cfs times two is what? 10 MS. KIPPS: 6,600. 11 MR. O'LAUGHLIN: Times 15 days? 12 MS. SENITTE: The question is: Did she have the 13 opportunity to make that calculation? 14 MS. KIPPS: I did not. 15 C.O. STUBCHAER: Please route your objections through 16 the Chair. 17 MS. SENITTE: Mr. Chairman, the question was: Did she 18 have the opportunity to make that calculation? And I don't 19 believe she was given the opportunity to respond to that. 20 C.O. STUBCHAER: Try again. 21 MR. O'LAUGHLIN: Did you, prior to issuing your 22 opinions and conclusions, go back and check whether or not 23 the Newman Wasteway had the capability to carry the 24 recirculation water set forth in Table 5 and provided to you 25 by DWR in SJRGA Exhibit 102? CAPITOL REPORTERS (916) 923-5447 10848 1 MR. GROBER: I don't believe we limited. 2 MS. KIPPS: No. 3 MR. O'LAUGHLIN: You didn't limit it? 4 MR. GROBER: We didn't look at that. It was not a 5 consideration. 6 MS. KIPPS: We were focusing on the monthly time step. 7 We did try splitting the months and trying to model the 8 split month, the 15 days of the month. But we were -- we 9 decided it was too complicated, and we decided to stick with 10 the monthly model. We were just looking for differences 11 from the base. 12 MR. O'LAUGHLIN: In regards to that, on Table Number 7, 13 run number 16, it says that 50 percent withheld in DMC 14 recirc years. 50 percent of what, Ms. Kipps? 15 MS. KIPPS: Flows from tile drainage. The component of 16 the Grasslands drainage that goes in the San Joaquin River 17 that we attributed to tile drainage. 18 MR. O'LAUGHLIN: That would be tile drainage only; is 19 that correct? 20 MS. KIPPS: In run 16, yes. 21 MR. GROBER: Yes. 22 MR. O'LAUGHLIN: In that run, can you tell me is there 23 somewhere in your report that would quantify the amount of 24 water that would have to be withheld in -- or withheld by 25 farmers or tile drainage or wherever it is going to be held, CAPITOL REPORTERS (916) 923-5447 10849 1 that would not make its way into the San Joaquin River under 2 run 16 in thousands of acre-feet? Do you have that in your 3 report? 4 MR. GROBER: That would be in Table 2. 5 MR. O'LAUGHLIN: I am there. Where in Table 2 is it 6 expressed the amount of tile drainage for a given month that 7 would have to be withheld? 8 MR. GROBER: It would be 50 percent of the months that 9 indicate the tile drainage was held, so 50 percent of the 10 March/April. 11 MR. O'LAUGHLIN: Where -- I am on Table 2. That is the 12 Grasslands watershed input data component per water year 13 type? 14 MR. GROBER: Yes. In the cross-section there is DSA 15 subsurface agricultural discharges, tile drainage, on a 16 monthly basis, showing the volume and the concentration of 17 the tile drainage for wet, above, the below, normal and dry 18 and critical dry years. 19 MR. O'LAUGHLIN: Well, when we come down to months, 20 March is the third month, I am assuming, as expressed 21 there? 22 MR. GROBER: Yes. 23 MR. O'LAUGHLIN: April is the fourth month? 24 MR. GROBER: Yes. 25 MR. O'LAUGHLIN: When we look at the amount of flow in CAPITOL REPORTERS (916) 923-5447 10850 1 acre-feet, then we would take half of that amount and 2 assume that is being withheld? 3 MR. GROBER: Yes. 4 MR. O'LAUGHLIN: What -- Ms. Kipps, in response to 5 questions in regards to the salinity that you used for the 6 water quality component that you used, I realize you lumped 7 them all together and you put them into the model. How is 8 it -- what would happen if those amounts that you used were 9 lower and the actual amounts were actually higher for 10 salinity? You used, I think, 250, 200 and I forget what 11 else you used. 12 MS. KIPPS: Could you repeat the question? 13 MR. O'LAUGHLIN: Sure. I'll go back and lay a 14 foundation. 15 In regards to assuming a water quality component for 16 the water coming from the Newman Wasteway, you assigned 17 particular values to that water; is that correct? 18 MS. KIPPS: That's correct. 19 MR. O'LAUGHLIN: Then you assigned particular values 20 based upon water year type; is that correct? 21 MS. KIPPS: Yes. 22 MR. O'LAUGHLIN: What would happen in your modeling if 23 the numbers that you used were actually lower than what is 24 actually occurring in reality? 25 MS. KIPPS: Without doing the model run, I would just CAPITOL REPORTERS (916) 923-5447 10851 1 think that it would result in a higher quality or lower 2 salinity at Vernalis. 3 MR. O'LAUGHLIN: If the numbers went in the opposite 4 way, would it result in a higher salinity at Vernalis? 5 MS. KIPPS: It would depend on how much higher it would 6 be. 7 MR. O'LAUGHLIN: Mr. Grober, I was confused about one 8 of the things. In regards to a question by Mr. Herrick you 9 stated that the value of the study that it would show that 10 flow objectives could be met on the San Joaquin River. 11 Do you remember stating that a couple of minutes ago? 12 MR. GROBER: Yes. 13 MR. O'LAUGHLIN: How is it that you come to that 14 conclusion when you do not know what the reservoirs on the 15 east side on the Stanislaus, Tuolumne and Merced Rivers are 16 doing since you have no input in your model for their 17 reservoir operations? 18 MR. GROBER: I was only stating that conclusion based 19 on the context and the models. So assumptions of the input. 20 And if the input is valid in terms of operation, given the 21 base case of this model, that layered on top of it, the 22 recirculation, the flow objectives could be met. 23 MR. O'LAUGHLIN: Why is it you only ran recirculation 24 when water quality -- let me go another way. 25 You made a statement that you ran recirculation only in CAPITOL REPORTERS (916) 923-5447 10852 1 the months that water quality was being met. 2 Do you remember that, Ms. Kipps? 3 MS. KIPPS: Yes. 4 MR. O'LAUGHLIN: Now is that when water quality is 5 being met without any add water from New Melones that we see 6 in the Tables 9A and 9B? Or do you already add the New 7 Melones water under Tables 9A -- 8 MS. KIPPS: No. That assumes that we got in DWRSIM for 9 the mouth of the Stanislaus -- could you repeat your 10 question? 11 MR. O'LAUGHLIN: Well, I am confused. Why don't we go 12 to an actual chart. Why don't we turn to Table 9A, 13 additional New Melones releases thousand acre-feet required 14 to meet Vernalis salinity objective, base case results, 15 South Delta Water Agency Exhibit 12. 16 Do you have that in front of you, Ms. Kipps? 17 MS. KIPPS: Yes. The question? 18 MR. O'LAUGHLIN: The question is: Look at -- let's 19 pick up at the top so we can read it. Let's go to 1924 in 20 April. Do you see that? It has 15,000 acre-feet. Do you 21 see that number? 22 MS. KIPPS: Yes. 23 MR. O'LAUGHLIN: When you did your modeling runs, did 24 you do a modeling run in 1924 for recirculation if there was 25 add water being made available from New Melones to meet CAPITOL REPORTERS (916) 923-5447 10853 1 additional water quality -- to meet Vernalis salinity 2 objectives? 3 MS. KIPPS: This was the output of the run. It wasn't 4 an input to the run. 5 MR. O'LAUGHLIN: What I am confused about is your 6 statement. You said you only ran recirculation when water 7 quality was being met at Vernalis. Why don't you try to 8 explain that. 9 MS. KIPPS: I will explain that. Our base run, we 10 generated salinity at Vernalis on a monthly basis from 1922 11 to 1994. We did a check to see if the salinity was below 12 the objective. Then, if there were add water as indicated 13 by the table that we got from DWR, then we would recirculate 14 it. If the Vernalis salinity was in excess of the 15 objective, we didn't recirculate it. We didn't do 16 anything. Because what we wanted to do is find out if it 17 made matters worse in those months where the salinity 18 objective was already met. 19 MR. GROBER: That is what is presented for run five. 20 MS. KIPPS: That is the one that is presented as run 21 five, Table 7, but in fact, that is run six. My apologies. 22 C.O. STUBCHAER: Was that with or without water from 23 New Melones for modeling purposes? 24 MS. KIPPS: DWRSIM runs that gave us the flows at the 25 Stanislaus, according to DWR, it had already the flows that CAPITOL REPORTERS (916) 923-5447 10854 1 were required, as DWR saw it, DWRSIM, that was necessary to 2 meet salinity objectives. 3 C.O. STUBCHAER: Including water from New Melones? 4 MS. KIPPS: Right. 5 MR. O'LAUGHLIN: So when I look at the base run, would 6 it be safe to say that you didn't run recirculation in the 7 months when water quality in March, April and May was not 8 being met? 9 MR. GROBER: The base run has no recirculation. 10 MR. O'LAUGHLIN: Let me turn to run five; you call it 11 run six now. 12 When you add that water in run five that was run, 13 recirculation was run so -- let me go back. Let's assume 14 something. Water quality is not being met at Vernalis, for 15 whatever reason. When you did your model running, whatever 16 -- let's take hypothetically the year 1997. You show up in 17 your model water quality is not being met, under your model, 18 the model would skip that year and go to year in which water 19 quality was being met and then run recirculation for run 20 five? 21 MS. KIPPS: Well, it is not so much the running of a 22 model. It's the creation of the input files that go into a 23 model. 24 MR. O'LAUGHLIN: Thank you. 25 MR. GROBER: That is a further question under the CAPITOL REPORTERS (916) 923-5447 10855 1 qualification. Because in the base run, already included 2 are releases to water quality under DWRSIM. This is water 3 that is calculated based on SJRIO, additional water that 4 would be required because of the differences in model. 5 MR. O'LAUGHLIN: In other words, this is additional 6 water on top of the water that is already being released 7 from New Melones to meet water quality so that the 8 assumption is that water quality is being met in all years 9 in all months at Vernalis? 10 MR. GROBER: Yes. 11 MR. O'LAUGHLIN: I have one quick question about Table 12 9A. When you went back and did this, did you ever try to 13 quantify if there were times when DWRSIM had a better water 14 quality than SJRIO so that negative numbers would show up on 15 Table 9A? 16 MS. KIPPS: I didn't do that. 17 MR. O'LAUGHLIN: Did you -- did anybody from the west 18 side tell you whether or not it was possible to hold back 19 the amount of tile drainage that you held back in run 16, 20 whether it was physically possible? 21 MR. GROBER: Once again, this is just a modeling 22 exercise. We didn't look in detail in terms of a physical 23 capacity in order to achieve that. 24 MR. O'LAUGHLIN: Is there an output in here that shows 25 that if you put recirculation on top of when water quality CAPITOL REPORTERS (916) 923-5447 10856 1 is being met that water quality is improved at Vernalis? In 2 other words, let's say we are not exceeding the standards. 3 We are in compliance. Is there an output here that shows 4 that if we do recirculation what the added benefit would be 5 to water quality at Vernalis for the months of April/May? 6 MS. KIPPS: This report does not contain that data. 7 MR. GROBER: Could you restate the question? 8 MR. O'LAUGHLIN: Sure. 9 My understanding is that if water quality is being met 10 and recirculation is being run through the system, Ms. Kipps 11 testified there was a benefit that water quality would 12 improve at Vernalis. I just wanted to know how much it 13 would improve at Vernalis. We are still within -- we are 14 still in compliance, but how much would it improve? 15 MR. GROBER: That is the results that are shown in this 16 report as run five. That is showing -- 17 I am sorry again for the confusion. Actually, that was 18 run -- should have been run six, what is presented here as 19 run five is actually run six is making releases, 20 recirculating only when water quality objectives are being 21 achieved, and what results here, which are correct for run 22 six, what they show is there is no change in water quality. 23 There is no improvement, but there is no degradation. 24 MR. O'LAUGHLIN: Let me ask a question, one last 25 follow-up on that, one last question. I know no one ever CAPITOL REPORTERS (916) 923-5447 10857 1 believes that, when an attorney says that, but I will try to 2 stick to it. 3 If in looking at this on these two runs with the DMC 4 recirculation case, and your response was that it doesn't 5 make it better. It doesn't make it worse. It makes it the 6 same. Would that change if we actually had water coming out 7 of the DMC that had higher salinity than what you ran in 8 your modeling assumptions? So if we bumped up salinity 9 coming out of the DMC to 450 or 550 or 600, would that still 10 ring through for run number five under Table Number 7, in 11 your opinion? 12 MR. GROBER: It depends completely on the magnitude. 13 It would certainly have an affect. That is where multiple 14 runs come from. 15 MR. O'LAUGHLIN: Thank you very much, Ms. Kipps and Mr. 16 Grober. 17 I have no further questions. 18 C.O. STUBCHAER: Staff -- let me find out. 19 Mr. Godwin, are you going to have redirect? 20 MR. GODWIN: No. 21 C.O. STUBCHAER: Let's finish. 22 Staff? 23 ---oOo--- 24 CROSS-EXAMINATION OF 25 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL CAPITOL REPORTERS (916) 923-5447 10858 1 BY STAFF 2 MR. HOWARD: The first question I have dealt with the 3 missing run five. I was -- I am curious if we can get a 4 copy of that into the record. I don't know if we can do 5 that or not. Perhaps this question should be directed 6 toward Barbara. 7 MS. LEIDIGH: Well, I think that staff can ask for it. 8 It would be something that the Regional Board would have to 9 produce, and I suppose it would be a staff exhibit rather 10 than the SJRGA exhibit. We would be asking for it. 11 Maybe you can answer the question whether or not you 12 would be able to. 13 C.O. STUBCHAER: The question that I would have is: 14 Can it come in at this time and be considered when it hasn't 15 been on the record for cross-examination purposes and things 16 like that? 17 MS. LEIDIGH: Well, all of the exhibits -- it would be 18 on the record for cross-examination purposes because Tom 19 Howard was asking a cross-examination about it. 20 C.O. STUBCHAER: Mr. O'Laughlin. 21 MR. O'LAUGHLIN: Maybe I can try it another way. I 22 would object to the introduction of run number five after 23 the close of Phase II, which is going to be today. That 24 would foreclose our opportunity to bring Mr. Grober and Ms. 25 Kipps back and ask them questions about run number five CAPITOL REPORTERS (916) 923-5447 10859 1 since we have not had the ability to cross-examine them on 2 that run, which is not in front of us. 3 C.O. STUBCHAER: That was the question I was going to 4 ask. 5 MR. HOWARD: I understand. If we can't do it, we can't 6 do it. I would still like to see it. 7 Getting at it in a slightly different way, in run 8 number 16 you show the reductions that are additive to run 9 number five upon adding tile drainage reoperation, as I 10 understand it. It is not possible by looking at it to tell 11 how much is due to the recirculation and how much is due to 12 the tile drainage reoperation. 13 Do you have any estimate of what the benefit is for 14 reoperation as opposed to recirculation? 15 MS. KIPPS: Run one has the recirculation. Run 16 has 16 the recirculation as run one and tile drainage, so you can 17 compare those two results. 18 MR. GROBER: Actually, run one can be used as an 19 indication of what the true run five should have looked at 20 in that there would be some improvement of water quality. 21 The difference is in terms of when that recirculation is 22 applied. 23 MR. HOWARD: I'd like to ask a couple questions 24 regarding the assumptions in Study 468A and why you chose 25 those assumptions. In 468A the assumption is made that -- CAPITOL REPORTERS (916) 923-5447 10860 1 or rather the water quality releases are already made out of 2 New Melones to meet water quality at Vernalis; is that 3 correct? 4 MS. KIPPS: According to DWRSIM. 5 MR. HOWARD: You decided to do a study in which you 6 determined how much water was required in addition to the -- 7 for the water required in the DWRSIM study? 8 MS. KIPPS: That was a result of the study. It wasn't 9 the major focus for the reason why we did the study. 10 MR. HOWARD: But you could have done a study in which 11 New Melones hadn't made any water quality releases yet. You 12 could have used that as your base case. Presumably you 13 chose not to. Could I ask why? 14 MR. GROBER: As simplification of time. It was just 15 the model that was available and for the types of results we 16 are getting, we didn't feel that it was necessary to do 17 that, though that would be a more exact measure that there 18 would be less discrepancy than what you would see in terms 19 of the required releases from New Melones. That would fall 20 out more directly. You would see the total releases 21 required in SJRIO. We just chose not to. 22 MR. HOWARD: The reason I ask is that -- could I have 23 SJRGA Exhibit 101 put up on the overhead, please. 24 I went through and counted briefly how many months 25 water was being added under this DWRSIM study to meet water CAPITOL REPORTERS (916) 923-5447 10861 1 quality. And in March it appears as though there are no 2 months in which water is being added under this DWRSIM study 3 to meet water quality at Vernalis. And in April 8 out of 4 the 73 years it is being added and in May 27 out of the 73 5 years it is being added. 6 Now, when I go to Table 7 -- could I have that up on 7 the screen -- when I look at your base case, I see that you 8 added water in March 29 percent of the time and April 25 9 percent of the time and May 16 percent of the time. 10 My general observation in the past has been that May is 11 a little drier than April and that water quality is often 12 exceeded in May more often than in April. But that is not 13 what your results are showing at all. In fact, they are 14 exact opposite. It seems to me that that is explained by 15 the fact that there is already substantial salinity control 16 water being put into the system from your DWRSIM input 17 model. 18 MR. GROBER: That's correct because we are showing 19 additional water that would be required on top of releases 20 that are already indicated as part of DWRSIM. In general, 21 SJRIO does estimate that more water is required in all 22 months. 23 MR. HOWARD: But you get a substantial -- if you had 24 done an operation study in which you had not included the 25 Vernalis salinity water in your input from DWRSIM, it seems CAPITOL REPORTERS (916) 923-5447 10862 1 like you would get potentially some substantially different 2 results in your subsequent runs. 3 MR. GROBER: Certainly. I am unable to give you exact 4 figures, but the range of figures, just as you say, would 5 show a rate of exceedance of 80 percent or some high level. 6 I don't want to give an exact number, but something much 7 higher than 16 percent in terms of the total rate of 8 exceedance for all May. It would be just as you indicate, 9 greater rates of exceedance in April and May than March, in 10 no small part because the objective is lower in April and 11 May than in March. 12 MR. HOWARD: One last clarification on another issue, 13 Table 2. You said that your 50 percent DMC study, your 50 14 percent tile water reduction study would be 50 percent of 15 the water in the column here listed "other non DSA," non 16 wetland discharges. 17 Would that be the total of this or just the tailwater 18 component of these? 19 MR. GROBER: This was just holding the tile drainage 20 component, just the first part. 21 MR. HOWARD: Which is a lot smaller than that number 22 you have listed here, actually? 23 MR. GROBER: The first subset on Table 2 on the left 24 side there is a component referred to as DSA subsurface 25 agricultural discharges, tile drainage. It would be those CAPITOL REPORTERS (916) 923-5447 10863 1 volumes shown in the flow column. 2 MR. HOWARD: I don't see that. Are we looking at 3 different tables? I am sorry, I have a different table. I 4 have another table called Table 2. You have two pages of 5 Table 2. That clarifies it. 6 MR. GROBER: That still indicates the flow component 7 for Table 2 for tile drainage. 8 MR. HOWARD: I have two Table 2s. 9 That is fine, thank you. That was all. 10 C.O. STUBCHAER: Anyone else? 11 Ms. Whitney? 12 Board Members? 13 Mr. Brown. 14 ---oOo--- 15 CROSS-EXAMINATION OF 16 SAN JOAQUIN RIVER GROUP AUTHORITY REBUTTAL 17 BY BOARD MEMBERS 18 C.O. BROWN: A couple, Mr. Chairman. 19 Was the California Aqueduct considered in your analysis 20 or was there any need, advantages or disadvantages, in 21 considering it in parallel with the DMC? 22 MR. GROBER: We were truly modeling. We kind of looked 23 at just the component we were looking at, which was just the 24 tile drainage -- just the recirculation. We didn't look at 25 outside sources. CAPITOL REPORTERS (916) 923-5447 10864 1 C.O. BROWN: You mentioned that the water quality 2 improves somewhat at Vernalis, but that it improves 3 substantially upstream of Vernalis. Could you give me a 4 rough idea of what you mean by "substantial"? 5 MS. KIPPS: I certainly will. In the conclusions, when 6 DMC was recirculated, the electrical conductivity at Crows 7 Landing decreases from 1200 microsiemens per centimeter to 8 about 773, so it is substantial reduction in salinity along 9 the main stem. 10 MR. GROBER: That example was given for the May pulse 11 flow. 12 C.O. BROWN: This may have been outside your study, but 13 if you have an opinion or did any work on the question I 14 would like to know your thoughts. 15 Could this alternative work in concert with any of the 16 other alternatives being proposed in the Draft Environmental 17 Impact Report in your opinion or have you read up on that? 18 MR. GROBER: I read a little bit, but I think I don't 19 even have to know a lot of specifics about the other 20 proposals/alternatives because this is showing just one 21 case, one example. It is just looking at it singularly 22 without a lot of other factors. But certainly something 23 like this could be just a component of it, could be 24 implemented or some variation of what is being proposed and 25 how it would coordinate with other things I think would have CAPITOL REPORTERS (916) 923-5447 10865 1 to be studied and specific other alternatives would have to 2 be looked at to see how they could be coordinated. In 3 general, yes, it could work with other proposals. 4 C.O. BROWN: That is all I have, Mr. Chairman. 5 C.O. STUBCHAER: Thank you, Mr. Brown. 6 Anyone else? 7 That concludes the cross-examination of this panel. 8 And thank you for your participation. We are going to do 9 the exhibits now. 10 You have something besides the exhibits, Mr. 11 O'Laughlin? 12 We are going to do the exhibits and then talk about 13 when closing briefs are due, and that will conclude Phase 14 II-A. 15 MR. O'LAUGHLIN: I would like to offer into evidence 16 SJRGA Exhibits 32 through Exhibit SJRGA Exhibit 88. 17 C.O. STUBCHAER: Please speak audibly and rise if you 18 want to be heard. 19 MR. NOMELLINI: Is that an offer of introduction on 20 behalf of Oakdale who Mr. O'Laughlin is representing today 21 or is it on behalf of San Joaquin River Group Authority who 22 Mr. Godwin is representing today? 23 C.O. STUBCHAER: You want to specify? 24 MR. O'LAUGHLIN: Yes, I would. As the Chairman would 25 remember, it was my witnesses. I was representing San CAPITOL REPORTERS (916) 923-5447 10866 1 Joaquin River Group Authority at the time that we went 2 through this testimony. 3 Due to the procedural aspects of how we have been doing 4 this, we wait until the end of the case and offer them. So, 5 I am offering them on behalf of the San Joaquin River Group 6 Authority, Mr. Chairman. 7 C.O. STUBCHAER: Staff agree with the numbering? 8 MS. WHITNEY: Yes. 9 C.O. STUBCHAER: Any objections to receipt of these 10 exhibits? 11 Seeing none, they are accepted. 12 Mr. Godwin. 13 MR. GODWIN: I would like to move into evidence SJRGA 14 Exhibit 100, 101 and 102. 15 C.O. STUBCHAER: Any objections? 16 Hearing none, they are accepted. 17 Thank you. 18 And our closing arguments are due 60 days after the 19 receipt of the transcript, Ms. Leidigh? 20 MS. LEIDIGH: They are due whenever the Board decides 21 they are. Originally we had been saying they would be due 22 in four to five weeks after receipt of the closing or the 23 last transcript. This last time when we were doing Phase V, 24 we had discussion in which we talked about taking a longer 25 time which was 60 days. But I think that perhaps the input CAPITOL REPORTERS (916) 923-5447 10867 1 of the parties would be helpful in setting the schedule. 2 C.O. STUBCHAER: Let's have some discussion on that. 3 But before we hear the discussion, I would like to say since 4 a lot depends on the outcome of Phase II and II-A, I would 5 like to see the period as short as is reasonable. 6 Mr. O'Laughlin. 7 MR. O'LAUGHLIN: I just wanted to remind everybody that 8 we will probably have to go back and be looking at the 9 record from Phase II, which is in large part a basis. 10 Because when SJRGA presented their case in Phase II-A, we 11 incorporated our testimony from Phase II. We have two 12 phases that will have been incorporated and done. The only 13 thing I would ask of the Chair is that we don't bunch up two 14 briefs at the same time, closing brief Phase V and a closing 15 brief for Phase II-A. 16 C.O. STUBCHAER: Any other comments? 17 Without objection, I think we will set the date for the 18 receipt of closing briefs on Phase II-A 30 days after the 19 receipt of final transcript. 20 Anything else? 21 MR. NOMELLINI: Can I verify if Central Delta Water 22 Agency 29 was admitted? 23 C.O. STUBCHAER: Ms. Whitney. 24 MS. WHITNEY: I don't believe it was, but I will check 25 in a second. CAPITOL REPORTERS (916) 923-5447 10868 1 MS. SENITTE: Can the witnesses be excused? 2 C.O. STUBCHAER: Yes, you may be excused, and thank you 3 again for your participation. 4 MS. WHITNEY: Yes, it was accepted on the 23rd. 5 MR. NOMELLINI: Thank you. 6 C.O. STUBCHAER: Any other business? 7 Mr. O'Laughlin. 8 MR. O'LAUGHLIN: Can we just set a firm date right now 9 because this concept of waiting until the Court Reporter is 10 done adds confusion. They are usually ten days, ten working 11 days. 12 It isn't? 13 C.O. STUBCHAER: Did that -- 14 MR. O'LAUGHLIN: It's time to go home. 15 C.O. STUBCHAER: This is a short day. Everybody should 16 still be fresh. 17 We are adjourned until next time. 18 (Hearing adjourned at 12:16 p.m.) 19 ---oOo--- 20 21 22 23 24 25 CAPITOL REPORTERS (916) 923-5447 10869 1 REPORTER'S CERTIFICATE 2 3 4 STATE OF CALIFORNIA ) ) ss. 5 COUNTY OF SACRAMENTO ) 6 7 8 I, ESTHER F. WIATRE, certify that I was the 9 official Court Reporter for the proceedings named herein, 10 and that as such reporter, I reported in verbatim shorthand 11 writing those proceedings; 12 That I thereafter caused my shorthand writing to be 13 reduced to typewriting, and the pages numbered 10754 through 14 10869 herein constitute a complete, true and correct record 15 of the proceedings. 16 17 IN WITNESS WHEREOF, I have subscribed this certificate 18 at Sacramento, California, on this 8th day of March 1999. 19 20 21 22 23 ______________________________ ESTHER F. WIATRE 24 CSR NO. 1564 25