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should be meaningful conservation, not needless hardship on districts and their landowneis. 

 The concern over these conservation criteria is resonating throughout the west, as nearly 

 identical, but clearly less strident criteria are proposed in other Reclamation states by the 

 Bureau of Reclamation. These other states will verify the inappropriateness of these criteria. 



Water users in the Friant Division believe in water conservation, and have led the nation in 

 pioneering water conservation techniques. We have learned, however, that the same 

 conservation measures simply cannot be applied to all water users. Individual circumstances 

 must be taken into account to develop a plan that best suits each district. A district should 

 not be obligated to prove that a given measure does not produce meaningful conservation, and 

 should not be required to implement a conservation measure until it is demonstrated to be 

 useful and cost effective. Unreasonable burdens on districts or water users should be avoided, 

 and proposed conservation measures should be subjected to cost/benefit analysis by the 

 Bureau to demonstrate that diey are economically feasible under the circumstances of each 

 district. Conservation plans must also take into consideration each district's size, probable 

 water supply, economic resources and other relevant factors \*1ien imposing imiform 

 conservation measures. The proposals you have made by virtue of your introduction of the 

 CVPRA would accomplish all of those goals while ensuring meaningful conservation efforts 

 on the part of CVP water users. 



Virtually all of the proposed revisions in the water conservation provisions of the CVPIA are 

 in response to unreasonable Bureau implementation of the existing law. CVP districts have 

 encountered extraordinary difficulties in processing water conservation plans, and have made 

 little progress in correcting those problems despite repeated efforts to work with the Bureau to 

 make implementation of the CVPIA water conservation provisions more balanced and 

 reasonable. Generally, and quite appropriately, the CVPRA does not pursue legislative 

 solutions to problems that can be addressed administratively. Where the Bureau has indicated 

 a genuine willingness to proceed administratively, CVP districts stand ready to work with the 

 Bureau to resolve CVPIA inyjlementation problems. However, that is not the case in water 

 conservation matters. The CVPRA is thus needed to facihtate meaningful water conservation 

 efforts under the CVPIA. 



Sununarv 



In summary of my statement today, let me again note my appreciation for your willingness to 

 once again address the issues of water management in the Central Valley Project of 

 California. 



The proposed changes in the CVPIA, as outlined in the CVPRA, represent a studied review 

 of the CVPIA, its implementation to date, and its chances for a successful implementation in 

 the future. The adjustments proposed by the CVPRA are needed and should be considered 

 the minimum required in order to make the CVPIA a workable law. There is considerably 

 more of the CVPIA that could have been, and maybe should have been, addressed by this 

 legislation. It was obviously assumed by the authors of the CVPRA that many of the other 



