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• District review and approval or denial of proposed water transfers are appropriate if based 

 on reasonable and objective criteria identified in a water transfer program developed by 

 the district or the Secretary. 



• Districts should be obligated to develop and implement a water transfer program that 

 facilitates water transfers under all hydrologic conditions if a formal request to transfer 

 water is submitted by a district landovmer. 



• The Secretary should establish a model water transfer program that districts may use in 

 developing their own water transfer program, and which, in the absence of a district 

 developed water transfer program, will be used by the Secretary to review and approve or 

 deny proposed water transfers. 



• An appropriate and timely appeal process to the Secretary should be provided to review 

 the objectivity and reasonableness of district water transfer programs and to review the 

 application of those criteria in deciding to approve or deny proposed water transfers 



• Districts that approve transfers based on groundwater substitutions are required to prepare 

 and implement a groundwater monitoring and response plan that ensures the transfer has 

 no significant long-term adverse impacts on groundwater conditions. 



• Transfers of prior rights water should be subject only to the $25 per acre-foot Restoration 

 Fund fee. 



• Exercise of the right of first refiisal on water transfers outside the CVP service area should 

 be continued. 



Comparison with H.R. 1906: 



H.R. 1906 is consistent with the Urban Coalition position in providing that 

 water districts should have the primary role in reviewing and approving transfers, and that 

 historic water transfers should be allowed to continue without increased administrative 

 burden. H.R 1906 proposes to eliminate the role of the Secretary of Interior in reviewing and 

 approving water transfers except with regard to their impacts on the ability of the CVP to 

 meet environmental obligations. This role appears to be too limited. The Urban Coalition 

 believes that the Secretary has an obligation to facilitate water transfers and should be 

 available for appeal to ensure that transfers are accomplished fairly and appropriately. 



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