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Part 2 Partners, Benefits & Payments February 27 – March 6, 2003.

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Presentation on theme: "Part 2 Partners, Benefits & Payments February 27 – March 6, 2003."— Presentation transcript:

1 Part 2 Partners, Benefits & Payments February 27 – March 6, 2003

2 2 Meeting Purpose & Agenda Meeting Purpose –Review how partners would work together, how the project would be paid for, and how the benefits can be quantified Agenda –2003 Studies: Information and Schedule –Current Project & Potential Expansion –CCWD Reimbursement (CCWD Principle #6) –Possible Institutional Structures (CCWD Principle #5) –Cost & Financing (CCWD Principle # 5 and #6) –Value of Benefits

3 3 Meeting Guidelines Ensure Everyone's Participation –One speaker at a time –Minimize side conversations Honor Our Time Limits –Keep comments concise and avoid redundancy – Use ditto to agree with others Commit to Being Fully Present –No cell phones, pagers, voicemail, etc. –Ask for what you need from the meeting process Respect Each Other –Listen carefully to other participants and try other opinions on for size –Respond to ideas and issues, not individuals Identify Yourself –State your name and organization or community

4 4 2003 Study Activities Extensive public outreach – Now through June 2003 Provide facts & information Key dates – CCWD Board decision -- July 2003 – Potential vote -- November 2003 Where we are now….

5 5 Public Workshops Today’s Discussion –Potential Project -- Partners, Payments, and Benefits Potential CCWD reimbursement from partners Organization structure and agreements among CCWD and potential partners Costs and financing options Valuing benefits for CCWD and potential partners Future Workshops –Part 3 -- Environmental Effects & Mitigation – Impacts and strategies for addressing potential adverse effects –Part 4 -- Review of CCWD Principles and responses to comments

6 Information Available Now PARTNERS, BENEFITS & PAYMENTS Reimbursement - Amount other partners would need to reimburse CCWD for shared facilities Benefits - Value of benefits for CCWD and potential partners (water quality, reliability, environmental, other) Institutional - Models for how other similar projects are owned and operated by participating agencies Financing - Financing costs and methods PARTNERS, BENEFITS & PAYMENTS Reimbursement - Amount other partners would need to reimburse CCWD for shared facilities Benefits - Value of benefits for CCWD and potential partners (water quality, reliability, environmental, other) Institutional - Models for how other similar projects are owned and operated by participating agencies Financing - Financing costs and methods

7 Information Available From Previous Workshops OPERATIONS Delta Water System - How the Delta water system works and how an expanded reservoir would operate with other partners Potential Partners - List of potential partners, their needs, and the benefits an expanded reservoir could provide them Water Rights - Description of water rights changes needed Water Quality - Benefits for CCWD and other Bay Area water agencies Reliability - Benefits for CCWD and other Bay Area water agencies Delta Environment - Environmental benefits for the Delta FACILITIES & COSTS Delta Intakes - Size of facilities, possible facility layouts for fish screens, and pumping capacity Pipelines - Capacity, corridors, and length Dam - Size, location, safety features, construction schedule, reservoir inundation area, and interim water supply plan Cost Estimates - Planning level construction and operation & maintenance costs OPERATIONS Delta Water System - How the Delta water system works and how an expanded reservoir would operate with other partners Potential Partners - List of potential partners, their needs, and the benefits an expanded reservoir could provide them Water Rights - Description of water rights changes needed Water Quality - Benefits for CCWD and other Bay Area water agencies Reliability - Benefits for CCWD and other Bay Area water agencies Delta Environment - Environmental benefits for the Delta FACILITIES & COSTS Delta Intakes - Size of facilities, possible facility layouts for fish screens, and pumping capacity Pipelines - Capacity, corridors, and length Dam - Size, location, safety features, construction schedule, reservoir inundation area, and interim water supply plan Cost Estimates - Planning level construction and operation & maintenance costs

8 8 CCWD Principles for Participation 1.The project improves water quality and reliability for CCWD 2.The project enhances the Delta environment 3.The project protects and enhances the fisheries and terrestrial species benefits provided by the existing Los Vaqueros Project 4.The project preserves and increases the recreational opportunities of the Los Vaqueros Project 5.CCWD must maintain control of watershed and operation of the reservoir 6.The project protects and reimburses the financial investment made by the CCWD customers who financed the existing $450 million Los Vaqueros Project 7.The proposal would be placed before the voters of the Contra Costa Water District

9 9 CALFED Objectives –Improve the Bay-Delta ecosystem –Improve water supply reliability –Improve water quality for all beneficial uses The CALFED Record of Decision specified the following for the Los Vaqueros Reservoir Studies: “Expand Los Vaqueros Reservoir by up to 400 thousand acre-feet…with local partners as part of a Bay Area water quality and water supply reliability initiative.” CALFED Implementation Commitment –Beneficiaries of the project shall pay for the project

10 10 Project Overview CALFED is studying whether an expanded Los Vaqueros Reservoir can meet CALFED and Bay Area water agencies’ objectives Water Quality Reliability Environmental Enhancement Expansion from 100,000 acre-feet up to 500,000 acre-feet maximum capacity

11 11 Existing Los Vaqueros Project Owned and operated by CCWD Provides Emergency Storage –Protects against a catastrophe in the Delta Improves Water Quality –Changes the timing and location of diversions –Stores water for blending when Delta water quality is poor Enhances Delta Environment –State-of-the-art fish screens –Flexible timing and location of diversion

12 12 Existing Los Vaqueros Project Old River Intake Facility Contra Costa Canal Los Vaqueros Reservoir & Watershed CCWD Service Area Rock Slough Intake Facility

13 13 Existing and Potential Facilities for an Expansion Project Delta Intake and Conveyance Delta-Los Vaqueros Pipeline & Pump Station LV-SBA Pump Station & Pipeline Dam and Recreation

14 14 Potential Partners Bay Area Water Agencies

15 15 Potential Partners CALFED Agencies Environmental Water Agencies –U.S. Fish & Wildlife Service –National Marine Fisheries Service –California Department of Fish & Game –U.S. Bureau of Reclamation –California Department of Water Resources

16 16 Questions and Discussion Workshop Process and Public Review –Available Information Existing Los Vaqueros Project –Benefits –Facilities –Ownership & Operations Potential Partners –Bay Area Water Agencies –CALFED Agencies

17 17 Agenda 2003 Studies: Information and Schedule Current Project & Potential Expansion CCWD Reimbursement (CCWD Principle #6) Possible Institutional Structures (CCWD Principle # 5) Cost & Financing (CCWD Principle # 5 and #6) Value of Benefits

18 18 Reimbursement to CCWD CCWD Principle #6 –The project protects and reimburses the financial investment made by the CCWD customers who financed the existing $450 million Los Vaqueros Project Interpretation –CCWD would share elements of the existing project needed for the expansion project –CCWD would be reimbursed for existing facilities that would be shared or rendered unusable –CCWD would retain sole ownership of some project facilities –CCWD would pay for its fair share of the new project Considerations –Reimbursement subject to negotiation with potential partners and CALFED

19 19 Reimbursement to CCWD Study Team’s initial analysis indicates CCWD’s net reimbursement would be between $100 and $200 million The CCWD Board of Directors would determine how to use this reimbursement –Reduce CCWD debt and water rates –Buy additional water quality or reliability benefits –Combination CCWD water rates would not increase as a result of the expansion

20 20 CCWD spent $450 million on the existing project

21 21 CCWD would retain ownership of facilities used only by CCWD Existing Project Elements Used Only By CCWD Conveyance –Transfer Pipeline (from reservoir) –Los Vaqueros Pipeline Watershed Property –Watershed lands not inundated

22 22 Partners would pay CCWD for existing facilities rendered unusable Dam Conveyance –Old River Pump Station –Transfer Pump Station –Transfer Pipeline (to reservoir) Impacted Recreation Facilities –Marina –Trails –Picnic Areas

23 23 Participants would share in the value of existing project elements that contribute to the expansion project Participant’s share will be determined by the extent they benefit from the project elements Existing Facilities –Old River Intake –Vasco Road Relocation –Utility Relocation –Watershed Improvements –Inundated Area Lands –Existing Mitigation

24 24 Participants, including CCWD, would pay their share of the expansion project costs New Facilities –Conveyance Delta Intakes & Pipelines Delta Pump Station Delta-Los Vaqueros Pipeline –Los Vaqueros-South Bay Aqueduct Pipeline & Pump Station –Recreation Facilities –Dam –Mitigation

25 25 Reimbursement to CCWD Methodology relies upon “beneficiary pays” commitment Actual reimbursement amounts depend on the size of facilities and negotiations with CALFED Agencies and potential partners These estimates are conservative so that the studies do not overestimate the potential reimbursement The analysis does not commit any party to a value, including CCWD, Bay Area water agencies or CALFED Agencies Existing Los Vaqueros Reservoir Project $450 Million Cost of the existing Los Vaqueros Reservoir $800 Million Project with inflation Net Reimbursement to CCWD$100 to 200 Million CCWD cost for share of new facilities $250 to 200 Million CCWD Recovery for existing facilities$350 to 400 Million 2008 Dollars Actual Dollars

26 26 Conclusions Reimbursement to CCWD This basis of cost sharing meets CCWD Principle #6 –The project protects and reimburses the financial investment made by the CCWD customers who financed the existing $450 million Los Vaqueros Project CCWD maintains benefits of existing reservoir and receives additional water quality and reliability benefits Based on these cost sharing principles, the analysis shows a reimbursement between $100 to $200 million to CCWD –Would depend on the benefits CCWD purchases –The CCWD Board of Directors would determine how to use this reimbursement –Subject to negotiation with potential partners and CALFED Agencies CCWD water rates would not increase as a result of the expansion

27 27 Questions and Discussion Reimbursement Approach Range of Reimbursement Rate Reductions and/or New Benefits

28 28 Agenda 2003 Studies: Information and Schedule Current Project & Potential Expansion CCWD Reimbursement (CCWD Principle #6) Possible Institutional Structures (CCWD Principle # 5) Cost & Financing (CCWD Principle # 5 and #6) Value of Benefits

29 29 CCWD Retains Control CCWD Principle #5 –CCWD must maintain control of watershed and operation of the reservoir Implementation –Identify possible institutional structures that could meet the CCWD Principle and potential partners needs Considerations –Subject to decisions by potential participants about their role in project financing and governance

30 30 Institutional Definitions Owners Governing Entity for Repayment Governing Entity for Repayment Operator Participants Entity that operates the facilities & receives payments for operations Entities that receive benefits of the project & make payments to the Governing Entity Coordinating entity that represents project participants One or more entities that finance the project & own the facilities

31 31 Existing Institutional Structure Los Vaqueros Project This arrangement would be retained for –Watershed lands not inundated –Recreation facilities –Other facilities used solely by CCWD Owner CCWD Owner CCWD Governing Entity for Repayment CCWD Governing Entity for Repayment CCWD Beneficiaries CCWD Customers Beneficiaries CCWD Customers Operator CCWD Operator CCWD

32 32 Existing Institutional Structure Contra Costa Canal Owner U.S. Bureau of Reclamation Owner U.S. Bureau of Reclamation Governing Entity for Repayment U.S. Bureau of Reclamation Governing Entity for Repayment U.S. Bureau of Reclamation Beneficiaries CCWD Customers Beneficiaries CCWD Customers Operator CCWD Operator CCWD

33 33 Existing Institutional Structure South Bay Aqueduct Owner California Department of Water Resources (DWR) Owner California Department of Water Resources (DWR) Governing Entity for Repayment California Department of Water Resources (DWR) Governing Entity for Repayment California Department of Water Resources (DWR) Participants SCVWD ACWD Zone 7 Participants SCVWD ACWD Zone 7 Operator DWR State Water Project Operator DWR State Water Project

34 34 Other Projects Reviewed Central Valley Project, California (Federal/Local) Cachuma Project, California (Federal/Local) Central Arizona Project (Federal/Local) Central Utah Project (Federal/Local) State Water Project, California (State/Local) San Luis Project, California (Federal/State) Hetch Hetchy Project, California (Local/Local)

35 35 Possible Partnership Arrangements Project ownership dependent on final project partners Bay Area water agencies could participate as owners or contractors CCWD would always be one of the owners Six institutional structure options identified

36 36 Federal Participation Participation Options –Owner –Governing Entity –Participant/Beneficiary Considerations –Project provides Federal benefits –Consistent with Federal planning guidelines –Subject to Congressional approval

37 37 State Participation Participation Options –Owner –Governing Entity –Participant/Beneficiary Considerations –May be subject to State Legislature approval –Could be part of the State Water Project

38 38 Local Water Agency Participation Participation Options –Owner –Governing Entity –Participant/Beneficiary Considerations –Fair & equitable agreements on project control and operations –Flexibility to share water to meet urgent needs –Subject to local water agency approval

39 39 CCWD Participation Participation Requirements –Owner –Governing Entity –Operator –Participant/Beneficiary Considerations –Fair & equitable agreements on project control and operations –Flexibility to share water to meet urgent needs –Subject to CCWD Board and customer approval

40 40 Example Institutional Structure Federal / State / CCWD / Local Owner Contra Costa Water District Owner Contra Costa Water District Environmental Water Account (or its successor) Central Valley Project State Water Project Contra Costa Water District Other Bay Area Water Agencies Environmental Water Account (or its successor) Central Valley Project State Water Project Contra Costa Water District Other Bay Area Water Agencies Operator Contra Costa Water District Operator Contra Costa Water District Owner Other Bay Area Water Agencies Owner Other Bay Area Water Agencies Owner U.S. Bureau of Reclamation Owner U.S. Bureau of Reclamation Governing Entity for Repayment Special District or Authority similar to Joint Powers Governing Entity for Repayment Special District or Authority similar to Joint Powers Owner California Dept of Water Resources Owner California Dept of Water Resources Participants Operations Contract Operations Contract Water Service and Exchange Agreement Water Service and Exchange Agreement

41 41 Example Institutional Structure Federal / State / CCWD / Local Most complex ownership scenario –Maintains CCWD control of operations and watershed –Meets Federal planning and authorization requirements –Consistent with State requirements –Includes specific agreements on control and operations for local water agencies All other scenarios provide a similar level of control for CCWD

42 42 Institutional Structures Conclusion & Discussion Conclusions –CCWD could maintain ownership of watershed and control of reservoir operations –Potential participants included in ownership, governance, and repayment agreements Each participant would determine their level of participation Questions & Discussion –Possible institutional structures

43 43 Agenda 2003 Studies: Information and Schedule Current Project & Potential Expansion CCWD Reimbursement (CCWD Principle #6) Possible Institutional Structures (CCWD Principle # 5) Cost & Financing (CCWD Principle # 5 and #6) Value of Benefits

44 44 Cost and Financing CALFED Implementation Commitment –“A fundamental philosophy of the CALFED Program is that costs should, to the extent possible, be paid by the beneficiaries of the program actions.” CALFED Implementation Commitment included in CALFED ROD Considerations - Repayment depends on selection of financing and repayment mechanisms

45 45 Financing Options Four probable sources of funds –Federal Appropriations –State General Obligation Bonds –State Revenue Bonds –Local Revenue Bonds Source and types of funding determined by each partner’s governing body Project would likely be financed by some combination of sources

46 46 Financing Options Federal Funds Federal Appropriations for Construction –Authorized by Congress –Through the U.S. Bureau of Reclamation –Financing costs can be lower than other options –Repayment based on share of benefits

47 47 Financing Options State Funds General Obligation Bonds –Approved by voters –Currently used to fund many CALFED activities –Debt service costs paid by State General Fund –Generally appropriate for projects with broad public benefits State Revenue Bonds –Approved by state legislature –Repaid from project revenue –Used to finance the State Water Project –Generally have higher financing costs

48 48 Financing Options Local Funds Pay-as-You-Go –No interest or debt service costs General Obligation Bonds –Generally require voter approval Revenue Bonds –Approved by local boards of directors –Some types may require voter approval Drinking Water State Revolving Loan Fund –Low interest loans for water utilities (up to $20 million per project)

49 49 Project Cost Estimate Cost includes the size of project elements: –Intake Facilities –Pipeline/Pumping Facilities –New Dam/Reservoir Facilities Reimbursement to CCWD for existing project investment not included –Additional $100 to $200 million Financing costs are not included Reservoir Size: Intake Size:

50 50 Conclusions Financing Options Financing methods are available for each of the potential partners –Bay Area water agencies would pay for the benefits they receive –CALFED Agencies would pay for environmental benefits The agencies would determine the method for financing environmental water actions CALFED and ultimately Congress and the State Legislature would determine how costs are repaid

51 51 Questions and Discussion Possible financing options –Federal –State –Local

52 52 Agenda 2003 Studies: Information and Schedule Current Project & Potential Expansion CCWD Reimbursement (CCWD Principle #6) Possible Institutional Structures (CCWD Principle # 5) Cost & Financing (CCWD Principle # 5 and #6) Value of Benefits –Summary of benefits –Methods used to value benefits

53 53 Part 1 Evaluation of Potential Benefits The Study Team evaluated varied ways of operating an expanded reservoir –Single purpose operations Delta environmental benefits only Bay Area water agencies drought reliability only –Multi-purpose operations Providing Delta environmental benefits and drought reliability –Drinking water quality improves for all operations

54 54 Part 1 Evaluation of Potential Benefits Multi-purpose operations maximize total benefits –Environmental and drought reliability benefits similar to each single purpose operation –Combined benefits greater than single purpose Facility sizes accomplish varied benefits –300,000 acre-foot reservoir Suitable size for single purpose operations –500,000 acre-foot reservoir with 1,000 cubic feet per second (cfs) intakes Suitable size for multi-purpose operations –Increasing intake size to 1,750 cfs Provides more flexible reservoir filling and reduced impacts to Delta environment

55 55 Benefits to CCWD Water Quality –High quality blending water to last through a 6-year drought Reliability –Up to 20,000 acre-feet of reliable water supplies in each year of an extended drought –Up to 120,000 acre-feet total of reliable water supplies over an extended drought Reimbursement –Between $100 and $200 million to purchase additional benefits or reduce CCWD costs

56 56 Benefits for Bay Area Water Agencies High water quality into the future –New intakes would reduce salts and bromide –Larger intakes allow faster reservoir filling when quality is better –Deeper reservoir with multiple intakes reduces algae –These improvements would improve taste, reduce treatment costs, improve the ability to meet existing and future water quality regulations, and reduce public health risks More reliable water supplies –Up to 60,000 acre-feet of reliable water supplies in each year of an extended drought –Up to 370,000 acre-feet total of reliable water supplies over an extended drought

57 57 Benefits to Delta Enhancement Expanded Los Vaqueros Reservoir Enhances Delta Environment – Reduces impacts to fisheries from existing SBA diversion State-of-the-art fish screens Flexible timing of diversion – Creates storage and flexibility for Environmental Water that could allow Shut downs at state and federal pumps when fish are present (up to 160,000 acre-feet per year) Water for wildlife refuges Water for in-stream flows upstream of Delta

58 58 Approach for Valuing Benefits The Study Team is developing an approach to assign a dollar value to each of the project benefits –Water Quality Consumer Benefits Agency Benefits Industrial Benefits –Reliability –Environmental Water –Recreation Approach –Coordinate with the CALFED Common Assumptions Group and the Bay Area water agencies –Estimate the dollar value of each benefit

59 59 Consumer Water Quality Benefits Consumer benefit: Reduced salts delivered to consumers –Lower total dissolved solids (TDS) and total hardness (TH) levels means household appliances and plumbing fixtures last longer, reducing consumer costs –Valuation of consumer benefit based on estimates of: Operations modeling of TDS and TH levels delivered Water quality improvement from Los Vaqueros Number of households with various types of appliances and plumbing Cost of appliances Increased longevity due to water quality improvement

60 60 Consumer Water Quality Benefits Consumer benefit: Reduced disinfection byproducts (DBPs) delivered to consumers –Current delivered water meets all water quality standards –Further reductions in DBPs can help meet more stringent future standards and improve public health –Valuation based on avoided cost of advanced water treatment to achieve the same benefits

61 61 Agency Water Quality Benefits Agency Benefit: Decreased costs for treating water –Costs decrease as bromides, turbidity, and total organic carbon (TOC) are lowered, and temperature fluctuations are reduced (pH and algae) Valuation of agency benefits based on estimates of: –Water quality levels in water delivered from Los Vaqueros –Lowered coagulant usage and ozone demand at WTPs –Improved operations –Lowered capital/replacement costs –Lower corrosion control costs

62 62 Agency Water Quality Benefits Agency Benefit: Decreased salts delivered to groundwater basins –Agency costs for managing salt balance in groundwater basin would be reduced Valuation of this benefit based on estimates of: –TDS delivered by Los Vaqueros –Avoided cost of future groundwater demineralization projects

63 63 Industrial Water Quality Benefits Industrial Benefit: Decreased salts delivered to industrial users –Lower heavy industry costs for treating boiler feed water and cooling water –Lower manufacturing costs for ultrapure water treatment Valuation of industrial benefits based on estimates of: –Reduction in TDS and TH levels in water delivered from Los Vaqueros –Volume of water used for each category of industry

64 64 Reliability Benefits Benefit: Increased reliability during dry periods Valuation of increased reliability based on: –Current costs of reliability supplies (e.g. transfers, Semitropic Groundwater Banking Program-Phase II, etc.) –Department of Water Resources tool for estimating the value of supply reliability projects –Benefit beyond 2030 capped at cost of desalination

65 65 Environmental Benefits Benefit: Reliable supply of water for environmental purposes Valuation of the benefit coordinated with the CALFED Common Assumptions Group, using: –Recent and projected costs of acquiring environmental water for current conditions –Avoided cost of water management options that would provide similar benefits after 2030 –Future benefit capped at cost of desalination

66 66 Recreation Benefits Existing recreation benefits would be expanded Valuation of recreation benefits based on estimates of: –The value of visitor days –The number of visitor days based on existing Los Vaqueros Reservoir and other comparable reservoir recreation usage Recreation activities include: Boat fishing Shore fishing Picnicking Hiking/Trail usage Interpretive Center usage ADA access facilities included

67 67 Benefits Conclusions Approach will assign dollar value for each benefit –Water Quality: consumer, agency, & industrial –Reliability –Environmental Water –Recreation Next: Refine approach and perform analysis –Continued coordination with the CALFED Common Assumptions Group and Bay Area water agencies

68 68 Conclusions Project Requirements An expanded Los Vaqueros Reservoir could meet CCWD Principles #5 and #6 –CCWD would retain control of the watershed and operation of the reservoir –An expansion project would protect and reimburse the financial investment made by the CCWD customers The project could meet CALFED objectives –Beneficiaries of the project would pay for the project

69 69 Questions and Discussion Benefits of an expansion project –Water Quality –Reliability –Environment Methods used to value benefits

70 70 Contact Information Marguerite Naillon Project Manager CALFED Los Vaqueros Reservoir Expansion Studies 2300 Stanwell Drive P.O. Box H2O Concord, CA 94524 Phone: (925) 688-8018 email: lvstudies@hotmail.com www.lvstudies.com

71 71 Next Steps Comments on Today’s Discussion –Due March 14 by e-mail or regular mail Future Workshops (see handout with schedule & locations) –Mid-April -- Environmental Effects & Mitigation -- Strategies for addressing potential adverse effects –Late May -- Summary and Response to Comments -- Review of CCWD Principles and answers to comments and issues

72 Information Available in April 2003 EFFECTS Delta Habitat and Fisheries - Impacts and benefits Delta Water System - Impacts to legal water users Land Impacts - Impacts and benefits for habitat and species in the watershed and along pipeline corridors, including impacts to previous mitigation Recreation - Impacts to recreation facilities in the watershed Cultural Resources - Impacts to cultural resources in the watershed Public Safety - Flood safety impacts downstream of dam MITIGATION & ENHANCEMENT Mitigation - Approaches for identified impacts Enhancement - Opportunities to achieve net benefit for biological resources and Delta environment Land Acquisition - Land needs for mitigation Reservoir Recreation Facilities - Replacement and new facilities EFFECTS Delta Habitat and Fisheries - Impacts and benefits Delta Water System - Impacts to legal water users Land Impacts - Impacts and benefits for habitat and species in the watershed and along pipeline corridors, including impacts to previous mitigation Recreation - Impacts to recreation facilities in the watershed Cultural Resources - Impacts to cultural resources in the watershed Public Safety - Flood safety impacts downstream of dam MITIGATION & ENHANCEMENT Mitigation - Approaches for identified impacts Enhancement - Opportunities to achieve net benefit for biological resources and Delta environment Land Acquisition - Land needs for mitigation Reservoir Recreation Facilities - Replacement and new facilities Mid-April

73 Information Available in Summer 2003 REVIEW CCWD PRINCIPLES Review of how each Principle can be met ISSUE RESPONSE Respond to issues raised by public, stakeholders, and other involved parties REVIEW CCWD PRINCIPLES Review of how each Principle can be met ISSUE RESPONSE Respond to issues raised by public, stakeholders, and other involved parties Late May


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