THOMAS BUSCHATZKE
Director

DOUGLAS A. DUCEY
Governor

ARIZONA DEPARTMENT o{WATER RESOURCES
mo West Washington Street. Suite 310
Phoenix, Arizona 85007
602.771.8500
azwater.gov

December 3, 2018

Re: Proposed Amendment to Implementation Plan
Dear President Atkins and Director Cesare:
First, I would like to thank CAWCD staff for their substantial contributions to the development of the
Implementation Plan as presented to the Steering Committee on November 29, 2018. As I said at the
Steering Committee meeting, I fully endorse the Implementation Plan as presented. Governor Ducey's
intention to include in his budget proposal $30 million in State funding of system conservation
demonstrates the Administration's commitment to the Implementation Plan.
I am writing to you regarding the "friendly amendment" to the Implementation Plan proposed by
Director Cesare at the meeting. I agree with the need to work to resolve the uncertainty regarding USF
to GSF transactions. In fact, the Implementation Plan assumes that those uncertainties will be resolved.
However, I cannot support the remainder of the proposed amendment for reasons that follow.
The amendment essentially proposes to reduce the 150,000 acre-feet of system conservation to be
funded by the State and non-governmental organizations (NGOs), instead diverting 75,000 acre-feet of
conservation to serve as the DCP Contribution that would otherwise come from CAP water users.
One of the strengths of the Implementation Plan is that it identifies a path forward while respecting the
objections expressed by stakeholders. During the Steering Committee process and small group
meetings, On-River Contractors have clearly stated that they view use of On-River supplies to meet the
DCP Contribution as an indirect transfer of water from the River to Central Arizona and strongly oppose
such a transaction. The proposed amendment ignores that concern by using On-River supplies to meet
the obligations that would otherwise come from Central Arizona.
Given Governor Ducey's proposal to include $30 million of upfront funding for system conservation and
the financial commitment from NGOs, it is clear that the necessary offset for use of CAP ICS will be
achieved while respecting the objections of On-River Contractors.

 December 3, 2018
Page2

Additionally, the proposal to include 7,000 acre-feet per year over three years for the CAGRD pool, if the
CAGRD- Gila River Indian Community- Gila River Water Storage, LLC, acquisition is not executed, is
unnecessary. My understanding is that the acquisition will be dependent on the authorization of the
DCP (and any necessary Implementation Plan components) by the Arizona Legislature. If the Arizona
Legislature fails to authorize the execution of the DCP agreements, then the Implementation Plan itself,
and any amendments to that plan, will also fail.
I believe the Implementation Plan is a viable path forward. I ask that you continue to work together with
us, and with all stakeholders, to finalize the Implementation Plan as originally proposed at the
November 29th meeting.

Director
cc:

Alexandra Arboleda
Jennifer Brown
Terry Goddard
Benjamin Graff
Jim Hartdegen
Jim Holway
Pat Jacobs
Mark Lewis
Heather Macre
Sharon Megdal
Pamela Pickard
Mark Taylor
Steering Committee Delegates
Ted Cooke