2.
Response
to
Comment
2.4
Master
Responses
to
Comments
Cumulative
analysis
of
the
flow
effects
of
the
water
transfer
on
the
Tuolumne
River
assuming
that
the
SFPUC
Water
System
Improvement
Program
is
completed
and
in
place.
Response
Overview
The
proposed
OID
water
transfer
is
described
in
the
Draft
EIR
in
Chapter
3,
Project
Description
(page
3-2
and
Section
3.10,
pages
3-66
through
3-68).
Under
the
proposed
water
supply
agreement,
the
City
would
acquire
a
supplemental
water
supply
of
up
to
2,400
acre-feet
per
year
(AFY)
via
a
water
transfer
agreement
with
OID.
OID
and
the
City
of
Brisbane
have
signed
a
term
sheet
that
establishes
the
framework
for
a
proposed
water
supply
agreement
for
the
potential
future
transfer
of
up
to
2,400
AFY
annually
for
a
50-year
period,
with
the
potential
for
renewals
for
additional
25-year
periods.
The
2,400
AFY
includes
up
to
2,000
AFY
to
serve
the
Baylands
and
400
AFY
to
accommodate
planned
growth
within
the
balance
of
the
City
of
Brisbane.
As
proposed,
water
would
be
transferred
from
OID
to
Brisbane
pursuant
to
water
supply
and
conveyance
agreements
to
be
executed
among
OID,
MID,
the
SFPUC,
and
the
City
of
Brisbane.
Only
existing
diversion
rights
and
existing
facilities
would
be
used
for
the
proposed
water
transfer;
no
new
facilities
would
be
built.
In
accordance
with
the
term
sheet
between
OID
and
Brisbane,
Brisbane
will
be
responsible
for
securing
the
transfer
agreement
with
MID
and
the
wheeling/conveyance
agreement
with
the
SFPUC.
OID
Water
Rights
and
Water
Supply
The
majority
of
OID’s
water
supplies
come
from
pre
-1914
surface
water
rights
that
enable
OID
to
divert
up
to
257,074
AFY
from
the
Stanislaus
River
at
Goodwin
Dam
upstream
of
the
City
of
Oakdale
without
restrictions.
Pre-1914
water
rights
represent
the
most
senior
appropriative
water
rights
in
the
state;
they
pre-
date
the
state’s
formal
water
rights
permitting
process,
now
administered
by
the
State
Water
Resources
Control
Board
(SWRCB),
and
therefore
are
not
subject
to
the
same
level
of
state
regulation
as
are
rights
acquired
subsequent
to
1914.
OID
does
not
need
approval
from
the
SWRCB
to
transfer
water
under
its
pre-1914
water
rights.
Steps
and
Parties
Involved
in
Implementing
the
Water
Transfer
The
method
of
water
delivery
to
Brisbane
set
forth
in
the
proposed
agreement
is
illustrated
in
the
schematic
below.
It
is
important
to
note
that
the
transfer
of
OID
water
from
MID
to
the
SFPUC
is
accomplished
through
a
crediting
process
rather
than
actually
moving
surface
water
from
the
Stanislaus
River
into
the
Tuolumne
River
system.
Some
comments
expressed
concern
about
the
water
quality
effects
of
co-mingling
water
supply
from
two
different
sources;
however,
this
would
not
occur.
In
this
transfer
process,
MID
would
use
some
of
OID’s
surface
water
from
the
Stanislaus
River
in
lieu
of
its
own
water
supply
from
the
Tuolumne
River.
Through
a
credit
exchange
process,
MID
would
credit
the
SFPUC
with
an
additional
amount
of
Tuolumne
River
water.
The
SFPUC
would
physically
convey
the
additional
Tuolumne
River
water
into
its
regional
water
system
and
deliver
the
additional
amount
to
Brisbane.
Brisbane
Baylands
Final
EIR
2.4-78
May
2015
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