PART X.

Kampa proposed establishing six reserve accounts which will obviously require increasing existing rates & fees along with creating a number of new customer fees.  How much of an increase?  Not known yet – months of study and research to be done first.   wonderful.

Sorry, but I must ask once again:

Why should Merced River water entitled customers of the subdivision pay for a special benefit water service requiring GROUNDWATER SUBSTITUTION from extremely expensive and often undependable wells in this drought prone, fractured rock, foothill area?

Shouldn’t those OUTSIDE MID-POU land developers pay for ALL EXPENSES REQUIRED to produce their special benefit water service which they need and use?

What is so difficult to understand here?  Of course if the District would simply post on its new and improved website the official MERCED IRRIGATION DISTRICT PLACE OF USE MAP FOR MERCED RIVER WATER USE UNDER WATER LICENSE 11395, most folks would understand the problem of what this GROUNDWATER SUBSTITUTION PROGRAM is intended to serve.

Imagine if this substitution special benefit policy is approved by the board…..and later when these ground wells fail and need major work or complete replacement – guess who will be on the financial hook?  

UNETHICAL AND SIMPLY WRONG

This makes no sense since the entitled Merced River water using customers in the Lake Don Pedro subdivision (99% of customers) do not need this special benefit groundwater replacement program. 

 

What is groundwater substitution?

What ever amount of Merced River water that leaves the use area permitted under the water license (essentially the Lake Don Pedro subdivision & golf course) must be replaced with an equal or greater amount of groundwater.  

Example:  IF 5 acre feet of Merced River water (1,629,265 gallons) is pumped from Lake McClure, treated at the LDPCSD plant and then distributed to a neighboring subdivision located OUTSIDE the legal place of use under the water license, 5 acre feet (1,629,265 gallons) or more, would have to be pumped from a ground well source and delivered to the treatment plant as replacement for the river water diverted. 

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Subdivision properties DO NOT REQUIRE SUBSTITUTION as they are legal Merced River water users under water license 11395 held by the MERCED IRRIGATION DISTRICT, and have legally used river water since the district was formed in 1980.  Substitution is ONLY REQUIRED FOR PROPERTIES OUTSIDE THE LEGAL USE AREA UNDER L11395!

SIMPLE/FAIR SOLUTION:

The simple solution would be to form a “special benefit water service zone” [for all properties outside the MID-POU which cannot use Merced River water] where those receiving the special benefit of GROUNDWATER SUBSTITUTION pay for all the costs required to provide the service.  Those benefiting from groundwater substitution should be financially responsible for the monitoring, reporting, maintenance, repair, and of course, replacement of the ground well for that project.

Simply having the land developer drill a well and then deed it to the district only puts the district (and all customers not requiring substitution) on a substantial financial hook for perpetuity!  (Up to several hundred thousand dollars per well.)

All costs associated with this special benefit GROUNDWATER SUBSTITUTION PROGRAM should be PAID BY THOSE RECEIVING THE BENEFIT, therefore, those LAND DEVELOPERS should be the ones required to create and fund the appropriate reserve accounts needed to cover future repairs and replacement of the ground wells serving their project.

Simple and fair and to do otherwise is wrongfully taxing those not receiving the benefit.