Report 2022-106 Recommendation 4 Responses

Report 2022-106: Department of Water Resources: Its Forecasts Do Not Adequately Account for Climate Change and Its Reasons for Some Reservoir Releases Are Unclear (Release Date: May 2023)

Recommendation #4 To: Water Resources, Department of

To ensure that it can demonstrate effective oversight of State Water Project operations and efficient use of the project's water supply, DWR should, by May 2024, develop and implement a policy and set of procedures for documenting the following:

1. Its monthly and annual plans for operating the State Water Project, including the amount of water that it intends to release, store, and export.

2. The rationale behind its plans and an explanation of how the plans will help it to achieve the project's objectives.

3. A description of any changes that it makes during its operations that deviate from its plans.

4. The rationale for any changes that it makes, including the conditions that led to the change, the specific reason for the change, and any viable alternatives that it considered.

5. The degree to which it succeeds in achieving each of the project's various objectives on a monthly and annual basis.

Annual Follow-Up Agency Response From June 2025

In February 2025, DWR updated its Water Supply Guidelines to include a monthly and annual assessment (on an ongoing basis) of the degree to which SWP operations objectives have been met, plus steps to communicate the results of these assessments. These objectives include delivering water to meet minimum health & safety needs; preserving upstream storage for future dry year and drought protection; meeting regulatory requirements; delivering water based on priority; and maximizing diversion to storage and delivery of water supply. DWR assessed Water Year (WY) 2024 operations to determine the degree of success in meeting its annual objectives. The final SWP allocation for WY 2024 was 40%, providing water supply to all SWP contractors including amounts needed to meet human health & safety demands. DWR met all State, federal, and contractual requirements, both in the Delta and in the Feather River; made water deliveries for human health & safety, the environment, and for those who have senior water rights; maximized diversion to storage upstream and south of Delta, all within the constraints of State and federal regulatory requirements. DWR has been meeting with the State Water Contractors (SWCs) multiple times each month, sharing plans for SWP water operations and providing an overview of how actual and real-time conditions were trending compared to the previous month's plans. DWR also provides overviews of SWP water supply allocation studies and describes the important coordination with State and federal resource agency partners and the major factors that play a role in operational decisions each month. DWR provides regular updates on SWP water operations at public meetings before the California Water Commission, including a year-end report on DWR's success in meeting its annual objectives. DWR annually presents at the SWC Workshop a review of prior WY's hydrology, operations studies/plans, project exports, end-of-WY storage, regulatory compliance, and lessons learned.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

1. Monthly plans: see Water Supply Guidelines (February 2025) p. 5 t/m B. Annual plans: ibid t/m A.

2. Objectives are at ibid p. 4 t/m C. Plans at ibid t/m D.

3. Ibid p. 8 t/m B, p. 9 t/m A, and p. 11 t/m B.

4. Ibid p. 8 t/m B and p. 9 t/m A.

5. Ibid p. 10 t/m A and B, p. 11 t/m A.

1-Year Agency Response

In March 2024, DWR developed three policy and procedure documents. These are living documents that formalize the procedures for SWP water operations scheduling and SWP monthly and annual planning and will be reviewed and updated to address changing conditions, regulatory requirements, and operational agreements. The documents are further described below:

Clifton Court Inflow Scheduling: Formalizes the procedure to determine the inflow into Clifton Court Forebay (south Delta exports). This Project Operations and Maintenance Directive (POMD) describes the factors that inform the inflow schedules, the contract, regulatory, and statutory compliance requirements, and internal and external coordination, notification, and documentation for scheduling changes.

Oroville Complex Scheduling: Formalizes the procedure for the schedule development for total Feather River releases required for Feather River instream requirements, Bay-Delta water quality and outflow, water supply, and flood control operations. The POMD describes the factors that determine release schedules, contract and regulatory compliance requirements, internal and external coordination, notification, and documentation for scheduling changes.

Water Supply Guidelines: Formalizes the development of SWP monthly and annual water supply planning activities. The procedure describes the parameters that are considered for each planning scenario, operational strategies, communications, and a process to provide monthly updates to external parties for the purpose of providing an overview of conditions that resulted in changes in the planning studies from month to month. The Water Supply Guidelines set forth potential contingencies in response to drought conditions and when there is limited water supply to meet all objectives.

Additionally, DWR has implemented the use of an internal operations report to enhance the documentation of the rationale for operations and changes to those operations.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

DWR provided documentation that did not provide information on the degree to which DWR succeeds at achieving its various objectives on a monthly and annual basis. Until it provides documentation demonstrating this is the case, we will report this recommendation as not fully implemented.

6-Month Agency Response

DWR continues to develop a policy to further document its practices and procedures related to water operations. DWR has implemented the use of a new internal operations report to enhance documentation of the rationale for operations and changes to those operations. DWR is on track to implement Recommendation No. 4 by May 2024.

California State Auditor's Assessment of 6-Month Status: Pending

We look forward to evaluating DWR's implementation of this recommendation when it provides its new policy and procedures as well as examples of its internal reports demonstrating that it has implemented each element of the recommendation.

60-Day Agency Response

The Department of Water Resources (DWR) will enhance our formal documentation on the development of SWP water supply planning studies procedures as well as the rationale for real-time operating procedures. DWR is exploring alternative methods to make this information publicly available.

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2022-106

Agency responses received are posted verbatim.