Nor is "choice" a category used by the 1974 Soil Survey. Rather, "Capability Classes" are used. Only soils in Capability Classes I through IV are considered amenable to cultivation, even with very careful management and selection of crops. El Dorado County was deemed to have no soils in Class I. Class II soils were only very sparsely represented (4447 acres, 0.6% of the total 539,065 acres covered in the 1974 Soil Survey). They are considered to have moderate limitations that reduce choice of plants and require moderate conservation practices. Class III soils comprised a little over 32,000 acres and 6.1% of the surveyed area. They are considered to have severe limitations that reduce choice of plants and/or require special conservation practices. Class IV soils comprised somewhat over 85,000 acres and 15.5% of the surveyed area. They are considered to have very severe limitations that reduce choice of plants and/or require very careful management. (To be compared with Wood Rodgers' figures, all the foregoing acreages would have to be adjusted by changes in land use that have occurred since the early 1970s when the surveying was carried out. And insertion of suitability for irrigation would further reduce the 1974 numbers.)

Moreover, the tallies on Figure 4-1, p. 4-16, include a category of slopes between 15% and 50% to comprise the total of allegedly "choice" irrigable soils, which fails to agree with the listed characteristic of up to 45%. This needs clarification. (See also Table 4.7, which contains the same inconsistency.)

• Data on actual water use lump vineyards with "Christmas trees, olive/citrus, berries, etc."(footnote "d", Table 2-10, p. 2-11). Thus there are no data to substantiate a figure of 1.3 afa/acre for vineyards. There is only an average including all the other listed crops. In some parts of the county, grapes apparently are grown without any irrigation, even drip.

• Wood Rodgers assumed (p. 4-19, Table 4-8, footnote "b") growth rates in irrigated agriculture of 7% for the years 2000 to 2010, 5% for 2010 to 2025, and 2% for 2025 to 2050. But actual EID data (metered agricultural water) for 2000 to 2003 shows expansion rates of less than 2%. Thus there is already evidence that the assumed growth rate is unjustified. The basis for the Wood Rodgers' assumptions needs examination and correction. Trends in conversion of land use have been more of agricultural land to other uses than of other uses to agricultural land. The FMMP program even lists four conversions of irrigated farmland to urban land in the 2002 update, all of them in the Camino/Apple Hill area.

• Expansion of vineyards also must be examined relative to long-term economic viability in light of the current depressed market for grapes attributed to overplanting, advent of the glassy-winged sharpshooter as a vector for transmission of Pierce's disease, and other factors. There is historical precedent for a need to consider long-term viability: Extensive pear orchards of El Dorado County's historic past disappeared as a result of disease.

• The Fairplay area is projected by Wood Rodgers to undergo considerable agricultural expansion. Except for the small Grizzly Flats area (served by a local system of limited capacity), the Fairplay area is now outside EID's service area. Cost of bringing piped or ditch water (and the extensive losses, of both water and money associated with the latter) must be examined as a function of the ability of only a few customers to pay, especially for necessary infrastructure, as well as relative to effects on the environment.

• Agricultural profit margins are slim now, according to agricultural spokesmen before the EID board of directors not long ago relative to projected rate increases. Agricultural water now is appreciably subsidized, mostly by residential customers. How much expansion of irrigated agriculture would these customers be willing to pay for in their own rates? Yet Wood Rodgers' report assumes (see Chapter 4, p. 4-13, Sec. 4.5, paragraph 2) that "reliable, affordable water supplies" were to be available. This, too, needs examination as to probability.

Many present agricultural operations aren't under Williamson Act contracts, causing one to wonder at a genuine long-term commitment to agriculture on the part of the operators. At least one grower has an investment in real-estate speculation. Given the slim profit margins, the attraction of greater profit in development proposals must be considerable. Money derived from real-estate speculation is easier to split among heirs than is a family agricultural business that may not even be attractive to all offspring.

Other Comments:

There is little addressing of "management" despite the title of the plan. Some suggestions , however, are included in the following comments:

Unaccounted-for water and water use/conservation: P. 2-2 gives an unaccounted-for loss of 13% for EID. Information presented on p. 2-7 shows a loss of 34.5% for Georgetown Divide Public Utility District. (Similarly, information on p. 2-8 yields a figure of 26% for Grizzly Flats Community Service District, but the overall use is so low that no further consideration will be given here.) As the state's population continues to increase, with water supplies thus increasingly limited, unaccounted-for losses become more and more unacceptable. The county's long-term management plan should consider this.

For EID, the El Dorado Hills area has a higher unaccounted-for rate than the more easterly service areas. This is quite surprising because the plumbing is largely new - it is, after all, the area where most of the county's growth is occurring. This issue should be explored with EID and the results incorporated into the Plan with a goal of reducing losses.

Discussions with GDPUD also should take place and the district pressured to develop and institute plans to reduce its losses. These plans should also be incorporated into the Plan.

The El Dorado Hills area is also a concern relative to consumption of water. Increasingly, its usage per household has been trending upwards. (This trend is concealed by use of average consumption over a period of years. EID's current water advisory committee - see below - may make recommendations that correct this situation.) This trend has been despite the increasing availability of recycled water for landscape irrigation. (Note also that not all golf courses use recycled water. As a management plan, the present Plan should consider inclusion of a goal that all golf courses, especially new ones, be required to use recycled water.) This trend may be related to both the prevalence of landscaping requiring irrigation (especially lawns) in comparison with more eastern service areas, and the preponderance of high-end houses, even McMansions, with luxurious bathroom facilities. Some of the fanciest installations use so much water that they require oversized water heaters and oversized drain pipes to accommodate the flows.

As part a management plan, the draft Plan should also consider the foregoing. Even a steeply tiered rate structure won't accomplish conservation if money is no object. Alternatives should be considered. Could a cap be put upon the amount of water, based perhaps on house and lot square-footage, a sort of "life-line" amount that, if exceeded, would trigger a very sharp increase in cost? Low-flow shower heads are too easily changed. Spas and Jacuzzis can=t be forbidden. How do other water purveyors handle this problem? Limited water supplies and increasing population will demand answers in the not too distant future.

Rate structure should be considered in another way, as well. For instance, some EID customers get water, sometimes even treated water, for aesthetic ponds at low, agricultural rates. In recent years, EID's "domestic irrigation" rate has been a source of controversy, to be gradually phased out by some boards and then reinstated by others. The origin of this rate was to encourage use of water when there was concern about "use it or lose it@. As adequacy of supplies tightens, this approach no longer makes sense.

Consistency with the General Plan: Only the four so-called "equal-weight" alternatives are even mentioned. All four, however, fail to conform with state and federal air-quality requirements, among other drawbacks. This may dictate consideration of one of the other eight alternatives. At any rate, we don't yet know what the new general plan will be so it is hard to understand how assurance can be given that the draft Water Plan will be "consistent" with it.

Dependency upon possibly flawed data: Criticism was heard in EID's citizens' water supply advisory committee of both the concept of "firm yield" and actual numbers in EID's recent water supply v. demand reports. Although no recommendations of the committee have been made public, in its deliberations it appears to be headed toward making revisions in both these factors. If so, these should be reflected in the Water Agency's Plan.

Omission of discussion of SMUD's Upper American River Project: The disconnect with the ongoing efforts of the County to get more water through the SMUD relicensing process is notable. The County has been pressuring SMUD to make more water available to the county through existing and proposed facilities included in its Upper American River Project. In view of the controversial nature of the proposed Alder Creek Reservoir, no mention of the SMUD efforts is a striking omission.

Global warming: Omission of any discussion of the possible effects of global warming upon the present water supply system is, in our view, quite serious. Moreover, the conversion of land to irrigated agriculture often (as in the case of the Duarte vineyard) involves destruction of natural woodland cover. Such destruction contributes, by the loss of a carbon sink, to global warming, as well as to impacts on wildlife habitat. Such factors should be included in a cost-benefit analysis of conversion of existing land use to irrigated agriculture. A recently released report on the effects of global warming on the Sierran water supply stated that research has found that the snowpack is melting earlier (spring and summer runoff in the southern Sierra has dropped 10 percent in the past century) and the elevation of snowfall is rising, among other effects. Such effects can have profound implications for existing water-supply systems.

Crawford Ditch: Mention of Crawford Ditch is encountered in both the listing of present water sources and as a possible new source to service the (we believe inflated) projected new agricultural demand in the Fairplay area. In the listing of existing sources of water, 5000 afa is claimed as entitlement/storage for Crawford Ditch (the second of two Source 4s). But when a challenge of EID's water rights went to the State Water Resources Control Board several years ago, the staff report reduced the entitlement to around 650 afa. In view of the potential for eventual adjudication of the claimed amount, it seems folly to claim 5,000 afa.

Losses in ditches, including Crawford, are highBone reason why EID is phasing them out. Examining EID's figures as to amount diverted and amount delivered to customers suggests losses in Crawford Ditch of as much as 80% or more, despite spending a reported $8 million several years back in repairs to reduce losses. Moreover, there is increasing concern at the degraded nature of the Cosumnes such that increased - and even present - diversions are likely to come under detailed scrutiny. It is unlikely that agriculture could pay the true cost of water obtained because of additional infrastructure necessary to utilize this source, even should added water rights be granted. At any rate, this topic should be examined.

Proposed Alder Reservoir/drought protection: We have already said that this proposed reservoir is likely to prove very contentious, and for a number of reasons. Arguments for it generally emphasize drought protection. An impression left is that those pushing it for this reason want 100% protection, which we believe to be both unrealistic and unwarranted. When a drought occurs, everybody should "share the pain" and conserve as much as possible for the common welfare. Present supplies should not be committed up to the very edge (as they seem to have been in the El Dorado Hills area, as an example). Suspicion that drought is only an excuse, and development (agricultural or otherwise) is the real purpose is rampant. Such suspicion is reinforced by the lack of any attempt that we know of to quantify how much water would be needed as a reserve. Other means of protection should be examined.

To lose the very scenic site to a reservoir, severely affecting wildlife habitat, endangering a unique population of native rainbow trout and, most likely, of Mountain Yellow-Legged Frogs in the process, and having a considerable effect on flows in the South Fork American River, along with its aquatic ecosystem would be a very high price to pay.

Proposed partition of "Fazio" water: Reportedly the 50:50 split of this water is based upon an agreement between EID and GDPUD several years ago to share the "paperwork" costs of getting this water in equal parts, rather than on any estimate of actual need. Questions of how GDPUD would utilize water to be taken at Folsom Lake remain unanswered, as well. Most growth in the county is occurring in the El Dorado Hills area, not in the service area of GDPUD. We think the basis for the split should be less arbitrary than it seems to be.

Miscellaneous:

Again, thank you for this opportunity to comment.

Sincerely,

Alice Q. Howard Conservation Chair