Free Motion in Limine - District Court of Federal Claims - federal

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AD Consultants
EXPERT REPORT of Avry Dotan Principal, AD Consultants In Connection with: Stockton East Water District et al. v. United States Court of Federal Claims Case No. 04-541L

July 26, 2006

15 Sullivan Drive . Moraga . California 94556 . U.S.A . (925) 631-9890 . Fax: (925) 631-9790 E-Mail: [email protected]

Case 1:04-cv-00541-CCM
Avry Dotan

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TABLE OF CONTENTS 1 2 INTRODUCTION .................................................................................................. 5 QUALIFICATIONS................................................................................................ 5 2.1 Education.............................................................................................................. 5 2.2 Employers............................................................................................................. 5 2.3 Summary of Experience with Hydrologic Modeling............................................... 5 2.4 Experience Specific to the San Joaquin and Stanislaus River Systems ............... 6 2.5 Previous Expert Witness Experience.................................................................... 7 2.6 Compensation....................................................................................................... 8 3 4 5 PURPOSE OF THIS REPORT ............................................................................. 8 SUMMARY OF CONCLUSIONS .......................................................................... 8 DESCRIPTION OF NEW MELONES MODEL (NM Model) .................................. 9 5.1 Methodology ....................................................................................................... 10 5.2 Assumptions ....................................................................................................... 12 5.2.1 5.2.2 5.2.3 Hydrology................................................................................................. 12 Characteristics of Facilities ...................................................................... 15 Diversion and Release Schedules ........................................................... 19

5.3 Sources of Information........................................................................................ 20 5.4 Model Validation ................................................................................................. 23 6 7 8 OPERATIONS STUDIES.................................................................................... 28 RESULTS ........................................................................................................... 28 CONCLUSIONS ................................................................................................. 31

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TABLE OF FIGURES Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 Schematic Diagram of the NM Model.......................................................... 10 Stanislaus River at Goodwin ­ True Natural Flow ....................................... 14 New Melones Area-Storage Curve.............................................................. 16 New Melones Dam Outlets Capacity........................................................... 16 New Melones Flood Control Rule Curve ..................................................... 17 New Melones and Tulloch Evaporation Rates............................................. 17 Tulloch Area-Storage Curve ........................................................................ 18 Tulloch Dam Outlets Capacity ..................................................................... 18 Tulloch Flood Control Rule Curve ............................................................... 19

Figure 10 New Melones ­ Historical vs. Simulated Historical Operation ..................... 25 Figure 11 Tulloch ­ Historical vs. Simulated Historical Operation ............................... 25 Figure 12 Total Goodwin Release ­ USBR data vs. HEC-5Q data ............................. 26 Figure 13 Differences in USBR data vs. HEC-5Q data for Total Goodwin Release .... 26 Figure 14 Total Goodwin Diversion ­ USBR data vs. HEC-5Q data............................ 27 Figure 15 Differences in USBR data vs. HEC-5Q data for Total Goodwin Diversion... 27 Figure 16 New Melones Reservoir Operations Assuming Full Allocation to Plaintiffs . 29

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TABLE OF TABLES Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Summary Results .......................................................................................... 8 Allocations of Diversion and Release as Provided by the USBR................. 20 Diversion to Plaintiffs Assuming Full Allocation (Model Input) ..................... 20 Data and Sources of Information................................................................. 22 Diversion to Plaintiffs - Available vs. Historical ............................................ 30 Goodwin Release ­ Defined and Actual for Historical and Full Allocation... 30

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1 INTRODUCTION
I, Avry Dotan, submit this expert report in the case Stockton East Water District et al v. United States, United States Court of Claims, Case No. 04-541L, at the request of Plaintiffs' counsel.

2 QUALIFICATIONS
A summary of my experience is attached hereto as Exhibit A. A summary of my publications is included in Exhibit A. 2.1 Education · M.S. · B.S. 2.2 Civil Engineering (1983) - University of Minnesota Civil Engineering (1981) - Technion, Israel Institute of Technology

Employers · 1990-Present: AD Consultants, Moraga, California (Principal) · 1987-1990: · 1984-1987: · 1982-1983: · 1981-1982: Morrison-Knudsen Company, San Francisco, California (Senior Engineer) Tudor Engineering Company, San Francisco, California (Senior engineer) Saint Anthony Falls Hydraulic Lab., University of Minnesota, Minneapolis, Minnesota (Research Assistance) TAHAL Consulting Engineering Inc., Israel (Engineer)

2.3

Summary of Experience with Hydrologic Modeling I have over 25 years experience in the development of computer simulation models for complex water supply, flood control and hydroelectric projects. I have extensive experience in all stages of model development: defining system characteristics, identifying a model's objectives, designing the program structure and algorithms, defining operation rules and objective functions, coding, calibrating and testing, documenting, developing user interface, implementing the model and providing training for the end user. I have developed and published numerous comprehensive computer programs for optimizing and sizing multi-purpose water and power developments including run-of-river, storage, pumped storage and off-stream storage hydroelectric projects. My models have received national recognition by engineering companies, utilities and private developers and have been used in the planning and modeling of over 50 projects throughout the United States. One of the more prominent models that I developed is the EBMUDSIM which is the primary longterm water supply planning tool that East Bay Municipal Utility District is using for its service area (approximately 1.3 million people).

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I have also authored several technical papers on the topic of state-of-the-art technologies in using computers in the planning of water and power projects. My work was published in technical conferences as well as civil engineering journals including CIVIL ENGINEERING and ENR. 2.4 Experience Specific to the San Joaquin and Stanislaus River Systems I have over 20 years of experience in modeling the San Joaquin River system including, the Stanislaus River, Tuolumne River, Merced River and the mainstem San Joaquin River. A more detailed description about aspects of this work relevant to my analysis for this case is provided in Section 5.3 - Sources of Information. The following are representative projects in the San Joaquin River basin for which I have provided modeling work: · Simulation models for the Stanislaus River related to the Bay-Delta Water Quality Control Plan proceedings. The work involved the analysis of the impact of the proposed alternatives by the State Water Resources Control Board on Oakdale and South San Joaquin irrigation districts. · STANMOD modeling in support of the Environmental Impact Report (EIR) for the Stockton East Water District (SEWD) Water Transfer Project. STANMOD is a computer model developed by the US Bureau of Reclamation (USBR) for long-term operations planning for the Stanislaus River system. · STANMOD modeling in support of the EIR for the South County Water Supply Project. The project involved simulation of diversion of water from Goodwin by South San Joaquin Irrigation District to a regional water treatment plant for further distribution to customers in the San Joaquin County service area. · Operations model of Beardsley, Donnells and Sand Bar projects on the Middle Fork of the Stanislaus River in connection with the power sales agreement between Tri-Dam Power Authority and Pacific Gas and Electric Company (PG&E). · Simulation model of water supply and power from New Melones and Tulloch Projects in connection with the US Federal Energy Regulatory Commission (FERC) Headwater Benefit Determination (the federal government collects money from Tri-Dam for the additional generation of power at Tulloch power plant realized from the construction of New Melones Dam). · Modeling of the Old Melones Reservoir and Power Plant in connection with Old Melones Power Plant condemnation by the federal government. · Simulation models for evaluating the feasibility of proposed water and power development on the Stanislaus River. · Simulation model in support of FERC Preliminary Permit Application for power development at Goodwin Dam. · Simulation model for proposed water and power developments on the Clavey River, a tributary to the Tuolumne River. Tuolumne River is one of the three

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major tributaries to the San Joaquin River (the other two tributaries are Stanislaus River and Merced River). · HEC-5Q modeling for the CALFED1 sponsored Stanislaus-Lower San Joaquin Water Temperature Modeling and Analysis. HEC-5Q is a water quality model developed by the US Army Corps of Engineers, Hydrologic Engineering Center (HEC). · HEC-5Q modeling for the CALFED sponsored San Joaquin River Basin-Wide Water Temperature Modeling and Analysis. 2.5 Previous Expert Witness Experience I have previously provided expert witness testimony to the Solano County Water Agency in connection with the Putah Creek litigation. The work involved developing computer simulation model of Lake Berryessa and Putah Creek and conducting water availability analyses. I also testified at the trial for this case and subsequently supported the parties involved in reaching a settlement agreement. In addition, I have provided consulting services and analysis in connection with the following legal cases: · Participated in negotiating a settlement between PG&E - the power purchaser and Tri-Dam Power Authority - the owner, in relation to the Sand Bar Hydroelectric Project dependable capacity. My work included the reconstruction of unimpaired flow data for the Middle Fork Stanislaus River, the development of site-specific computer models to simulate the operation of Donnells and Beardsley Reservoirs and Sand Bar Power Plant, and the interpretation of licensing, contractual agreements, and environmental constraints. The model was used by both parties in reaching the settlement agreement. · Provided an independent assessment to PG&E of the energy generation from the Old Melones Hydroelectric Project. The work involved developing computer simulation models of the operation of the Old Melones Reservoir and Power Plant using detailed performance curves. Results of the study were used in the litigation case associated with the condemnation of the Old Melones Power Plant by the federal government. · Participated in negotiating a settlement between FERC and Tri-Dam Project related to Headwater Benefits Determination for the Tulloch Power Plant. The work included the review of operation scenarios, development of computer operations model of Old Melones and Tulloch reservoirs, cost analysis and assistance to Tri-Dam Project to reach an early conclusion of a settlement with the FERC. · Provided (ongoing) consulting services to Alexander Anolik, a professional law corporation, related to the Westpark litigation. The work involved assembling

The CALFED Bay-Delta Program is a collaboration among 25 state and federal agencies that came together with a mission: to improve water supplies in California and the health of the San Francisco Bay/Sacrament-San Joaquin River Delta.

1

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and leading a team of experts in the area of meteorology, hydraulics, hydrology, and sediment transport in evaluating a February 24, 2004 rainstorm event and the resulting flood that damaged over 50 homes in the WestparkLakeview-Parkside area in Daly City, CA. 2.6 Compensation I am being compensated at the rate of $250 per hour for my work on this case and $350 per hour for time spent testifying.

3 PURPOSE OF THIS REPORT
The purpose of this report is to: (1) Describe the computer model that I have developed to simulate the operations of the New Melones Reservoir and Stanislaus River and the ancillary facilities related to the issues in this case; (2) Determine, based on modeling runs, whether it was possible for the USBR to deliver to Plaintiffs up to 155,000 acre-feet of water each year from New Melones Reservoir, from 1993 through 2004.

4 SUMMARY OF CONCLUSIONS
I have concluded that, after making all releases and diversions from New Melones that were actually historically made, it was physically possible for the USBR to deliver 155,000 acre-feet of water to Plaintiffs each year.
Table 1 Summary Results

Calendar Year

Amount Available
af

Amount Actually Delivered
af

Difference

af

1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 Total

155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 1,860,000

0 0 8,567 29,470 50,793 64,169 61,117 35,135 31,305 21,745 12,056 16,366 330,722

155,000 155,000 146,433 125,530 104,207 90,831 93,883 119,865 123,695 133,255 142,944 138,634 1,529,278

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5 DESCRIPTION OF NEW MELONES MODEL (NM Model)
The New Melones Model (NM Model) is a computer model that I designed to simulate the operations of the New Melones Reservoir and Stanislaus River and the ancillary facilities related to the issues in this case. The NM Model essentially performs mass-balance calculations for New Melones Reservoir, Tulloch Reservoir and Goodwin Diversion Dam, given historical hydrologic conditions, prescribed diversions from Goodwin pool, and prescribed releases from Goodwin Dam to the Stanislaus River. Using the model, it is possible to demonstrate how the system operated in the past and what the potential impact on New Melones storage volumes would be had it been operated in a different manner. The model provides the capability to compare actual historical operations (provided by the USBR) to "what if" scenarios by changing input parameters (such as, diversion or release schedules) and examining the resultant impact on New Melones storage volumes over the simulation period. The model was designed on Microsoft Excel platform and it contains function and macros (Visual Basic code) to facilitate the computation process, as explained in the following sections.

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5.1

Methodology An overview of the system components and the simulation process in the NM Model is presented in the schematic diagram in Figure 1 below:

Figure 1 Schematic Diagram of the NM Model

NM Model
System Components and the Computation Process
Local runoff

New Melones
Evaporation

l ow I nf

Tulloch
Evaporation

Local runoff
l Re se ea

3 2
Mass Balance New Melones and Compute Actual Release*

Delta

Goodwin
Diversion (CSJW CD & SEWD) Diversion (OID & SSJID)
n n S Sa n u ui a aq J Jo

Vernalis

l Re

se ea

Mass Balance Tulloch and Compute New Melones Defined Release

1
Compute Tulloch Defined Release given Goodwin Diversions and Goodwin Defined Release

4
Mass Balance Tulloch and Compute Actual Release*

se l ea Re

v Ri e er

5
Compute Diversions and Goodwin Actual Release based on Tulloch Actual Release*
*Actual Release= Defined Release + Flood Control

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The major storage components modeled are: · New Melones Reservoir with storage capacity of approximately 2.42 million acre-feet (MAF) · Tulloch Reservoir with storage capacity of approximately 67 thousand acre-feet (TAF) · Goodwin Pool with minimal storage capacity (assumed zero in the model) The major diversion facilities modeled are: · Goodwin Diversion Dam with diversion canals to Oakdale Irrigation District (OID) and South San Joaquin Irrigation District (SSJID) · Stockton East Diversion Tunnel which diverts water from Goodwin Pool to the Stockton East Water District (SEWD) and Central San Joaquin Water Conservation District (CSJWCD) The simulation process is based on the mass-balance calculations for the abovementioned facilities. The basic concept in mass-balance calculations for a reservoir can be described by the following equation: Inflow ­ Outflow = Change in Storage Where: ! Inflow is the sum of: o River flow upstream of the reservoir (often a release from the upstream reservoir) o Local inflow to the reservoir (local runoff and side streams) ! Outflow is the sum of: o Diversion from the reservoir o Defined release downstream of the reservoir (fishery and water quality releases) o Flood Release (water that needs to be released to meet flood control requirements) o Evaporation from the reservoir ! Change in storage is the difference in storage volumes in the reservoir between two successive time steps

The NM Model uses a time step of one day which means that the mass-balance calculations are made on a daily basis. As shown in Figure 1, the computation process in the NM Model is as follows:

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1) The model computes the Defined Tulloch Release by adding up Goodwin Diversion and Goodwin Defined Release. Goodwin Diversion consists of all diversions from Goodwin Pool (a breakdown of those is provided in Section 5.2.3 below). Goodwin Defined Release consists of instream flow releases below Goodwin (a breakdown of those is provided in Section 5.2.3 below). Since the impoundment behind Goodwin Dam is relatively small with essentially no active storage (it is only being used as a diversion facility and not as storage facility), the model assumes negligible change in storage and negligible evaporation in the Goodwin Pool. 2) The model performs mass-balance calculations for Tulloch and defines how much water is needed from New Melones (New Melones Defined Release) in order to satisfy the Defined Release from Tulloch. 3) The model performs mass-balance calculations for New Melones and computes how much water to release (Actual Release). It should be noted that Actual Release from New Melones could be in excess of the Defined Release because of flood control requirements. On the other hand, the model has a built-in constraint to limit the release in order to prevent flooding the river channel below Goodwin Dam (a practice usually employed by reservoir operators). This constraint may cause encroachment into the flood control space in New Melones during extreme flood events. 4) The model performs mass-balance calculation for Tulloch given Actual Release from New Melones. The result of this mass-balance is Actual Release from Tulloch (Tulloch also has flood control requirements which are reflected in the operation). 5) The model divides the Actual Release from Tulloch between diversion and Goodwin Release depending on the prescribed schedules for the two. Flood flow is considered part of Goodwin Release. 5.2 Assumptions The following are the assumptions I used in the NM Model. The sources for the data are listed separately in Section 5.3. 5.2.1 Hydrology The analysis period that I selected corresponds to the time span subject in this case, i.e., January 1993 through December 2004. As I mentioned earlier, the time step I used for the simulation is one day and as such, all the inflow data are based on daily values. As a general practice, hydrologic data used in modeling of this type are presented in the context of a long term period, usually with respect to the True Natural Flow (TNF)2. The TNF is the flow in the river in absence of any manmade storage facilities or upstream diversion. This enables us to assess the

2

The True Natural Flow is sometime referred to as Full Natural Flow (FNF)

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wetness of hydrologic conditions in the analysis period relative to the long term period of record. Figure 2 shows the annual TNF in the Stanislaus River as computed at the Goodwin Dam site. The annual TNF is sorted by order of magnitude from the lowest to the highest thus allowing us to see how the individual years in the analysis period compare to the rest of the years of record (the values for the analysis years are highlighted in the table) . The values of the TNF are also presented in the form of a flow-duration curve. The curve shows the percent of the time the TNF in the river was equal to a certain value or whether is was in excess. For example: the flow in 2002 is 851 TAF and it corresponds to 65%. This means that in 65 percent of the years the TNF equaled to or exceeded 851 TAF. Also shown in Figure 2, is the average TNF for the long-term period (1,122 TAF) and the average TNF for the analysis period (1,282 TAF). This means that the annual average flow in the river for the analysis period was approximately 160 TAF, or 14%, higher than the long-term average. Other hydrologic data of concern are the inflow to New Melones from the Stanislaus River and local runoff, local runoff into Tulloch Reservoir, and evaporation from New Melones and Tulloch. The sources for those are described in Section 5.3.

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Figure 2
Year % Exc 1977 100% 1924 99% 1976 98% 1931 96% 1987 95% 1988 94% 1961 93% 1990 92% 1934 90% 1994 89% 1992 88% 1939 87% 1929 86% 1991 85% 1959 83% 1947 82% 1960 81% 2001 80% 1933 79% 1926 77% 1985 76% 1968 75% 1949 74% 1930 73% 1944 71% 1966 70% 1972 69% 2004 68% 1989 67% 2002 65% 1981 64% 1928 63% 1948 62% 1957 61% 1954 60% 2003 58% 1964 57% 1953 56% 1951 55% 1962 54% 1955 52% 1971 51% 1946 50% 1923 49% 1984 48% 2000 46% 1979 45% 1925 44% 1935 43% 1937 42% 1975 40% 1999 39% 1932 38% 1963 37% 1936 36% 1970 35% 1927 33% 1945 32% 1941 31% 1974 30% 1940 29% 1973 27% 1965 26% 1943 25% 1997 24% 1942 23% 1922 21% 1956 20% 1993 19% 1978 18% 1958 17% 1996 15% 1980 14% 1967 13% 1950 12% 1952 11% 1986 10% 2005 8% 1938 7% 1998 6% 1969 5% 1995 4% 1982 2% 1983 1% Ave 1920-2005 Ave 1993-2004 Ratio (%)

Stanislaus River at Goodwin ­ True Natural Flow
TNF 188 295 302 355 374 380 399 425 435 477 487 507 520 542 570 598 601 611 620 664 672 703 729 733 748 753 771 776 802 851 859 894 896 899 900 950 952 954 990 1018 1020 1037 1052 1060 1122 1161 1190 1191 1197 1279 1283 1301 1305 1313 1323 1327 1350 1376 1378 1378 1424 1428 1454 1482 1486 1496 1497 1545 1549 1586 1661 1748 1767 1822 1846 1875 1878 1888 1905 2122 2226 2356 2419 2983 1122 1282 114%

True Natural Flow (TNF) Stanislaus River At Goodwin Dam Flow Duration

3,000 2,900 2,800 2,700 2,600 2,500 2,400 2,300 2,200 2,100 2,000 1,900 1,800 Annual TNF (TAF) 1,700 1,600 1,500 1,400 1,300 1,200 1,100 1,000 900 800 700 600 500 400 300 200 100 0 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% % Time Flow Equalled to or Exceeded

Wetter

Dryer

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5.2.2 Characteristics of Facilities The characteristics of the facilities simulated in the model include constraints, capacities and rules that affect the operation of the system. New Melones Dam and Reservoir · Maximum storage capacity is 2.42 MAF · Water surface area as function of storage capacity - Figure 3 · Combined capacity of all outlet works (low level outlet, power plant, and spillway) as function of reservoir storage - Figure 4 · Flood control rule curve - (top of conservation pool by month mandated by the US Army Corps of Engineers in order to provide sufficient space to attenuate flood events) - Figure 5 · Flood releases limited by not allowing it to exceed a flow rate of 5000 cfs downstream from Goodwin Dam (which minimizes flood damages) · Reservoir evaporation rates on a Julian year (a scale of 365 days in a year) basis - (daily evaporation is computed by multiplying evaporation rates by the reservoirs water surface area) - Figure 6 Tulloch Dam and Reservoir · Maximum storage capacity is 67,000 AF · Water surface area as function of storage capacity - Figure 7 · Combined capacity of all outlet works (low level outlet, power plant, and spillway) as function of reservoir storage - Figure 8 · Flood control rule curve - Figure 9 · Reservoir evaporation rates assumed the same as in New Melones - Figure 6 Goodwin Diversion Dam and Pool · No active storage in Goodwin Pool · Capacities of OID and SSJID irrigation canals are assumed based on the level of historical deliveries. · Capacity of Goodwin Tunnel is assumed not to exceed 850 cfs and was based on designed specifications provided by SEWD. · No flood control rules and no capacity limitation for Goodwin Dam spillway (see above New Melones flood release constraints) · Negligible evaporation (assumed already accounted for in the measured release below Goodwin and diversions)

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Figure 3

New Melones Area-Storage Curve

New Melones Area-Storage Curve 16,000 14,000 12,000 Area (acres) 10,000 8,000 6,000 4,000 2,000 0 0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 Storage (af)

Figure 4

New Melones Dam Outlets Capacity

New Melones Outlets Combined Capacity (Low level outlet, power plant and spillway) 160,000 140,000 Outlets Combined Capacity (cfs) 120,000 100,000 80,000 60,000 40,000 20,000 0 0 500,000 1,000,000 1,500,000 Reservoir Storage (af) 2,000,000 2,500,000 3,000,000

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Figure 5

New Melones Flood Control Rule Curve
New Melones Flood Control

2,500,000 Top of Conservation Pool (af)

2,000,000

1,500,000

1,000,000

500,000

0 0 50 100 150 200 Julian Day 250 300 350

Figure 6

New Melones and Tulloch Evaporation Rates
Reservoir Evaporation Rates

0.35

0.30

Trend Line
0.25 Inches per Day

0.20

0.15

0.10

0.05

0.00 0 50 100 150 200 Julian Day 250 300 350

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Figure 7

Tulloch Area-Storage Curve
Tulloch Area-Storage Curve

1,600 1,400 1,200 Area (acres) 1,000 800 600 400 200 0 0 10,000 20,000 30,000 40,000 Storage (af) 50,000 60,000 70,000 80,000

Figure 8

Tulloch Dam Outlets Capacity
Tulloch Outlets Combined Capacity (Low level outlet, power plant and spillway)

200,000 180,000 Outlets Combined Capacity (cfs) 160,000 140,000 120,000 100,000 80,000 60,000 40,000 20,000 0 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 Reservoir Storage (af)

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Figure 9

Tulloch Flood Control Rule Curve
Tulloch Flood Control

80,000 Top of Conservation Pool (af) 70,000 60,000 50,000 40,000 30,000 20,000 10,000 0 0 50 100 150 200 Julian Day 250 300 350

5.2.3 Diversion and Release Schedules Diversion and Release schedules are driving the simulation model. As explained in Section 5.1, the NM Model computes the actual release from Tulloch and New Melones based on Goodwin Diversion and Defined Goodwin Release. The Diversion and Release schedules that I considered in my analysis are based on two data sets: 1) Historical diversion and release information provided to the Plaintiffs' counsel by the USBR. Specifically, the data in the Excel files titled: Nmacct_91_05.xls and interrogatory5_long.xls. 2) Information on "what-if" diversion to Plaintiffs SEWD and CSJWCD. The "what if" diversion for each year are the difference between 155,000 acre-feet (the contract amount for the two districts) and the actual amount delivered to the districts based on historical data. The information for item #1 above is summarized in Table 2 below. The data in this table do not include flood control spills as those are computed as part of the simulation. The information for item #2 above is summarized in Table 3 below.

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Table 2

Allocations of Diversion and Release as Provided by the USBR
OID/SSJID Year by OID/SSJID Year Transfer to Transfer to SEWD CSJWCD OID/SSJID CSJWCD CVPIA Section (b)(2) and Bay/Delta Flows Vernalis 0 0 0 0 0 0 0 0 0 0 0 0 af 135,683 33,463 136,653 117,011 79,575 129,134 133,010 98,819 69,705 70,245 67,732 76,030 CVPIA Section 3406 (g) and 3406(b)(3) af 0 37,137 12,169 0 49,954 49,970 64,405 18,785 33,364 25,974 33,180 29,341

SEWD af 0 0 4,003 15,197 23,256 41,103 34,437 7,377 5,558 3,493 2,210 2,761

Water Quality Ripon DO af 0 0 61,547 0 0 0 2,767 1,537 16,020 28,340 57,878 7,741

Water Quality Vernalis af 59,798 134,430 0 23,254 83 0 0 0 112,356 105,574 110,793 70,566

CADFG '87 Agrmnt. 98.3-302.1 af 95,298 99,745 97,640 292,784 301,527 302,083 302,033 308,085 110,926 96,865 99,134 99,348

CVPIA Section (b)(1) af

Year 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

af 0 0 0 0 0 0 4,120 32,960 23,600 34,200 30,000 28,200

af 0 0 0 0 0 0 0 0 0 12,250 15,000 10,000

af 480,985 467,480 482,278 564,336 514,838 513,871 506,962 476,652 479,427 506,620 477,384 516,349

af 0 0 4,564 14,273 27,537 23,066 26,680 27,759 25,747 18,252 9,846 13,605

Total

153,080

37,250 5,987,182

191,328

139,394

175,831

616,854 2,205,467

0 1,147,059

354,278

The data in the above table is also the basis for comparison with the simulation scenario that I studied in the model with the exception that Historical Allocation for CSJWCD and SEWD were augmented to provide Full Allocation of 155,000 acre-feet per year, as shown in the table below.
Table 3
Year 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 Total CSJWCD af 0 0 4,564 14,273 27,537 23,066 26,680 27,759 25,747 18,252 9,846 13,605 191,328

Diversion to Plaintiffs Assuming Full Allocation (Model Input)
Historical
SEWD af 0 0 4,003 15,197 23,256 41,103 34,437 7,377 5,558 3,493 2,210 2,761 139,394 Total af 0 0 8,567 29,470 50,793 64,169 61,117 35,135 31,305 21,745 12,056 16,366 330,722

Full Allocation
CSJWCD af 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 960,000 SEWD af 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 900,000

Difference: Full-Historical
Total CSJWCD af af 155,000 80,000 155,000 80,000 155,000 75,436 155,000 65,727 155,000 52,463 155,000 56,934 155,000 53,320 155,000 52,241 155,000 54,253 155,000 61,748 155,000 70,154 155,000 66,395 1,860,000 768,672 SEWD af 75,000 75,000 70,997 59,803 51,744 33,897 40,563 67,623 69,442 71,507 72,790 72,239 760,606 Total af 155,000 155,000 146,433 125,530 104,207 90,831 93,883 119,865 123,695 133,255 142,944 138,634 1,529,278

5.3

Sources of Information I am currently the acting project manager for the CALFED sponsored StanislausLower San Joaquin River Temperature Modeling and Analysis (ERP-P28-02). This project was initiated by the Stanislaus stakeholder group in 1999 with the objective to study the relationships between Stanislaus River operation, water temperature, and fish mortality in the river- specifically, fall-run Chinook Salmon and Steelhead Rainbow Trout. Members of the stakeholders group included the U.S. Bureau of Reclamation (USBR), Fish and Wildlife Service (USFWS),

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California Department of Fish & Game (CDFG), Oakdale Irrigation District (OID), South San Joaquin Irrigation District (SSJID) and Stockton East Water District (SEWD). For the purpose of this project, we have implemented the HEC-5Q model to the Stanislaus River and the Lower San Joaquin River System and are currently (under contract extension) in the process of implementing it for other tributaries of the San Joaquin River, the Tuolumne and Merced rivers, and to the main-stem San Joaquin River. The HEC-5Q is software designed by the US Army Corps of Engineers to simulate reservoir operations and temperature response in the reservoirs and streams. HEC-5Q can be used to evaluate options for coordinating reservoir releases among projects to examine the effects on flow and water quality at specified locations in the system. Examples of applications of the flow simulation model include examination of reservoir capacities for flood control, hydropower and reservoir release requirements to meet water supply and irrigation diversions. The HEC-5Q is a well established computer model that has been applied to numerous river systems in the United States and world-wide. Specifically in California, the model is currently being used for modeling the Russian River (Sonoma County Water Agency), Sacramento River System (USBR), StanislausLower San Joaquin River (CALFED), and the Friant-Upper San Joaquin River (USBR). One of the interrelated tasks in the CALFED project was the development of operating scenarios for the Stanislaus River taking into consideration the river's hydrology, reservoir operating rules, and water demands throughout the system. Water demands include diversions from the river and instream flow release from Goodwin Dam for fisheries and water quality objectives. In my analysis for this legal case, I have relied upon data and modeling work developed for the CALFED project. Although most of the data used in the CALFED project were obtained from public sources, for the purpose of this report all data or assumptions that I used in developing the NM Model that were based on the CALFED project are tagged below as "CALFED". The other computer model I used as a source of information is STANMOD. STANMOD is a spreadsheet-based model developed by the USBR. The model allows for simulating the operations of New Melones and Tulloch reservoirs given projected water demands and operational agreements in the basin. STANMOD has been one of the primary modeling tools that the USBR used for scheduling water in the Stanislaus River during the period 1993 to 2004. Data or assumptions that I used in developing the NM Model that were based on the STAMOD model are tagged below as "STANMOD". Another source of data I used is allocation of water to the various water users and purposes, provided to the Plaintiffs' counsel by the USBR. Specifically, the

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data in the Excel files titled: Nmacct_91_05.xls and interrogatory5_long.xls. These data are tagged below as "USBR". As described later, in Section 6, I decided to extend the simulation period from 2004 through June-2006. Data for that period, as well as Goodwin Tunnel capacity, were obtained and tagged below as "SEWD". Finally, other data that I used are from other public sources, including: California Data Exchange Center - "CDEC" (data from stream and reservoirs monitoring stations managed by the State of California) and the US Geological Survey "USGS"- (data from stream and reservoirs monitoring stations managed by this federal agency). The following is a list of the primary data and assumptions I used in my studies and the corresponding sources of information.
Table 4 Data and Sources of Information Source CALFED CALFED CALFED/ CDEC/USBR USBR CDEC USBR/CDEC/SEWD CALFED STANMOD CALFED CALFED SEWD CALFED CALFED CDEC/USGS

Data/Assumptions New Melones Inflow Local Inflow to New Melones and Tulloch Historical New Melones and Tulloch Storage Historical Release from Goodwin Dam (by user) Historical Release from Goodwin Dam (totals) Historical Diversion (by user) Historical Diversion (totals) Percent Distributions of Annual Allocation to SEWD/CSJWCD New Melones and Tulloch Evaporation Rates New Melones and Tulloch Outlets Capacities Goodwin Tunnel Capacity New Melones and Tulloch Flood Control Rules New Melones and Tulloch Reservoirs Area-Storage Relationships Stanislaus River True Natural Flow at Goodwin Dam Site

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5.4

Model Validation Model Validation is an important step in assessing the model's accuracy before using it as a tool for predicting the trends or responses to changes in system operation. It should be recognized that models are not reality; they are merely mathematical representations of limited reality. As such, they only produce relative responses to changes in the input. Therefore, any reasonable inaccuracies of the model should not skew the results of the model when comparing alternative operating schemes for the system. For the NM Model I decided to validate the model in two ways: 1) By simulating the operation of the system using historical diversion and release from Goodwin and comparing the simulated storage in New Melones and Tulloch with the observed storage for those reservoirs. 2) By comparing the results of the NM Model with results of a similar model that have already been validated for this particular system. To accomplish this I have input the operational data provided to the Plaintiffs' counsel by the USBR to the NM Model (consisting of recorded allocation to the various water users as described in Section 5.2.3), and compared the simulated storage for New Melones and Tulloch reservoirs with: 1) The historical (observed) values 2) Simulated values from the HEC-5Q model (see Section 5.3). I have selected the HEC-5Q for NM Model validation for several reasons: · This model has already been validated and peer reviewed by CALFED and the Stanislaus Stakeholders, including the USBR. · The model has the same level of resolution in modeling the operation of the Stanislaus River as the NM Model (reservoir operation is modeled using a one day time step while temperature response in the system is modeled using 6hour intervals). · The model is well established, documented and available in the public domain. · The USBR is currently using the HEC-5Q for modeling water temperature in the Sacramento River system and for the Friant-Upper San Joaquin River litigation case. Results of NM Model verification are presented in Figure 10 for New Melones and Figure 11 for Tulloch. The results show that the NM Model tracks the HEC5Q results very well and both models track the historical operation reasonably well. Possible explanations for the discrepancies between the NM Model (and HEC5Q) results and historical values are: · The models cannot "duplicate" all decision making by operators in real time. For example: operators might have drawn down the reservoirs more aggressively in reaction to flood events or assumed more risk by allowing
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encroachment into the flood control space, facility maintenance could also require in some cases a draw down in storage to allow access to spillway gates, etc. · Error in the recorded data caused by faulty instrumentation or human error in recording the data. · Inaccuracies in estimating reservoir evaporation, local runoff, and other water unaccounted for such as seepage from dams, channel losses, etc. · Inaccuracy of the data provided to us by the USBR. For the last possibility, I have examined two parameters that are most relevant to my study: 1) Total Goodwin Release 2) Total Goodwin Diversion For both parameters I have compared the data that we received from the USBR with the data which was developed for the CALFED project (labeled on the charts as HEC-5Q). In the CALFED project, the Total Goodwin Release was obtained from CDEC, while the Total Goodwin Diversion was computed by mass-balance calculations for Goodwin Pool. The comparison is presented in terms of the flow distribution over the study period (1993-2004) and in terms of the cumulative difference between those values over the same period. Figure 12 through Figure 15 present this comparison and show negligible differences in Total Goodwin Release (approximately 6,000 AF over the 12-year period, or on average, about 500 AF per year), with a more pronounced difference in Total Goodwin Diversion (approximately 71,000 AF over the 12year period, or on average, about 6000 AF per year). These discrepancies in addition to the other factors discussed above, could provide some explanation for the deviation in storage between historical and simulated for New Melones, as presented in Figure 10 below. Nevertheless, these discrepancies are not detrimental, in my opinion, to neither the validity of the data used nor to the model's results and the conclusions of this study. As explained in Section 7 and Section 8 of my report, New Melones storage never reached low enough levels that the magnitude of the discrepancies discussed above could have result in drying up the reservoir.

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Figure 10
2,500,000

New Melones ­ Historical vs. Simulated Historical Operation

2,000,000

1,500,000 Storage (af) 1,000,000 500,000

Period of Dispute 0 1/1/1992 1/1/1993 1/1/1994 1/1/1995 1/1/1996 1/1/1997 1/1/1998 1/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005 1/1/2006 1/1/2006

Historical

Flood Control

Simulated Historical - HEC5Q

Simulated Historical - NM Model

Figure 11
70,000

Tulloch ­ Historical vs. Simulated Historical Operation

60,000

50,000

Storage (af)

40,000

30,000

20,000

10,000 Period of Dispute 0 1/1/1992 1/1/1993 1/1/1994 1/1/1995 1/1/1996 1/1/1997 1/1/1998 1/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005

Historical

Flood Control

Simulated Historical - HEC5Q

Sinulated Historical - NM Model

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Figure 12

Total Goodwin Release ­ USBR data vs. HEC-5Q data
Goodwin Release 14,000 12,000 10,000
Flow (af)

8,000 6,000 4,000 2,000 0 1/1/1993 1/1/1994 1/1/1995 1/1/1996 1/1/1997 1/1/1998 1/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005

Goodwin Release (USBR) (af)

Goodwin Release (HEC-5Q) (af)

Figure 13

Differences in USBR data vs. HEC-5Q data for Total Goodwin Release
Cumulative Difference in Goodwin Release (HEC-5Q - USBR)

150,000 100,000 50,000 0 -50,000 1/1/1993 1/1/1994 1/1/1995 1/1/1996 1/1/1997 1/1/1998 1/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005

Volume (af)

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Figure 14

Total Goodwin Diversion ­ USBR data vs. HEC-5Q data
Goodwin Diversion 14,000 12,000 10,000
Flow (af)

8,000 6,000 4,000 2,000 0 1/1/1993 1/1/1994 1/1/1995 1/1/1996 1/1/1997 1/1/1998 1/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005

Goodwin Diversion (USBR) (af)

Goodwin Diversion (HEC-5Q) (af)

Figure 15

Differences in USBR data vs. HEC-5Q data for Total Goodwin Diversion
Cumulative Difference Goodwin Diversion (HEC-5Q - USBR) 150,000 100,000 Volume (af)

50,000 0 -50,000 1/1/1993 1/1/1994 1/1/1995 1/1/1996 1/1/1997 1/1/1998 1/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005

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6 OPERATIONS STUDIES
The purpose of the operations studies was to determine, based on modeling runs, whether it was possible for the USBR to deliver to Plaintiffs 155,000 acrefeet of water from New Melones reservoir each year from 1993 through 2004. The general principle in these types of studies is to establish a base case, superimpose on it operating scenarios of interest, and then examine the relative change in the system response with respect to the base case. This so called "with and without" analysis is commonly used by water resources planners in assessing system's capability to meet future demands assuming the same pattern of hydrologic conditions as occurred in the past. In my analysis, I have established the base case by simulating the operation of the system using historical hydrology, historical diversion and historical instream flow below Goodwin. Then, I kept the hydrologic conditions the same and reoperated the system assuming different operating scenarios that reflect increased deliveries to the Plaintiffs, up to 155,000 acre-feet each year. It should be noted that although the period relevant to this case is 1993 to 2004, I have decided to extend the simulation period through June 30, 2006. This enabled me to assess the cumulative impact on New Melones storage had the USBR continue delivering the assumed water to the Plaintiffs through mid-2006, a time in which, historically, New Melones reservoir storage recovered and ended up spilling water. I also decided to start the simulation in January 1, 1992, as boundary conditions in the model.

7 RESULTS
The results of the operational study show that it was physically possible for the USBR to deliver 155,000 acre-feet of water to the Plaintiffs in each year from 1993 through 2004. Furthermore, the results show that had the USBR continued supplying 155,000 acre-feet per year to the Plaintiffs in the subsequent period, i.e., January 1, 2005 to June 30, 2006, it would not have dried up New Melones. In fact, New Melones would have still filled up to its maximum storage capacity, as actually occurred in the early summer of 2006. The results of the operations study are presented in the following figure and tables. The figure is a graphical presentation of the cumulative impact on New Melones storage had the USBR delivered 155,000 acre-feet to Plaintiffs each year from 1993 through 2004 (and through June-2006). The tables provide a summary of the operational values.

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Figure 16
2,500,000

New Melones Reservoir Operations Assuming Full Allocation to Plaintiffs

2,000,000

1,500,000 Storage (af) 1,000,000 500,000

Period of Dispute 0 1/1/1992 1/1/1993 1/1/1994 1/1/1995 1/1/1996 1/1/1997 1/1/1998 1/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005 1/1/2006

Historical

Flood Control

Simulated Full Allocation - NM Model

Figure 16 above shows that the maximum drawdown of New Melones under Full Allocation in comparison with the Historical operation would have been 661,647 af on 9/30/2004. This drawdown would result in New Melones storage volume to be at 448,959 af. The figure shows that New Melones storage starts recovering shortly thereafter, filling back to its maximum capacity and then spilling in the spring and early summer of 2006. The figure also shows that the minimum storage volume of New Melones during the dispute period would have been 118,248 af in September 1994, which is still 34,617 af higher than the minimum storage ever experienced in New Melones (83,631 af in the critically dry year of 1992).

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Table 5
Year 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 Total

Diversion to Plaintiffs - Available vs. Historical
Historical
CSJWCD af 0 0 4,564 14,273 27,537 23,066 26,680 27,759 25,747 18,252 9,846 13,605 191,328 SEWD af 0 0 4,003 15,197 23,256 41,103 34,437 7,377 5,558 3,493 2,210 2,761 139,394 Total af 0 0 8,567 29,470 50,793 64,169 61,117 35,135 31,305 21,745 12,056 16,366 330,722 CSJWCD af 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 80,000 960,000

Available
SEWD af 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 900,000 Total af 155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 155,000 1,860,000

Difference: Available-Historical
CSJWCD af 80,000 80,000 75,436 65,727 52,463 56,934 53,320 52,241 54,253 61,748 70,154 66,395 768,672 SEWD af 75,000 75,000 70,997 59,803 51,744 33,897 40,563 67,623 69,442 71,507 72,790 72,239 760,606 Total af 155,000 155,000 146,433 125,530 104,207 90,831 93,883 119,865 123,695 133,255 142,944 138,634 1,529,278

Table 5 above shows the shortfall of deliveries to the Plaintiffs by year during the period 1993 to 2004. The shortfall is computed by subtracting the Historical deliveries by the USBR from the Available water, as simulated with the NM Model. The total shortfall for the entire period is 1,529,278 af.

Table 6
Year 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 Total Historical af 290,779 304,774 314,763 433,049 431,139 481,186 502,215 427,226 342,371 326,997 371,738 283,027 4,509,265

Goodwin Release ­ Defined and Actual for Historical and Full Allocation
Goodwin Release - Defined
Full af 290,779 304,774 314,763 433,049 431,139 481,186 502,215 427,226 342,371 326,997 371,738 283,027 4,509,265 Diffrence af 0 0 0 0 0 0 0 0 0 0 0 0 0

Goodwin Release - Actual (simulated)
Historical af 293,725 304,774 318,015 1,008,129 1,239,991 1,249,123 818,826 517,846 342,371 326,997 371,738 283,027 7,074,563 Full af 292,480 304,774 316,631 459,116 1,227,987 1,050,219 818,432 427,226 342,371 326,997 371,738 283,027 6,220,999 Diffrence af 1,245 0 1,383 549,013 12,004 198,904 394 90,620 0 0 0 0 853,564 Historical af 2,946 0 3,252 575,080 808,852 767,937 316,611 90,620 0 0 0 0 2,565,298

Flood Release
Full af 1,701 0 1,868 26,067 796,848 569,032 316,217 0 0 0 0 0 1,711,734 Source Tulloch Tulloch New Melones New Melones New Melones New Melones New Melones

853,564

Table 6 above shows that the Defined releases from Goodwin are the same for both Historical conditions and Full Allocation conditions. The only decrease in Goodwin release is attributed to the reduction of flood release down the river. The total reduction in flood release for the entire period 1993 to 2004 is 853,564 af. This observation is very important as it provides insight on how the shortfall in supply to the Plaintiffs was eliminated in the model under the Full Allocation case: the shortfall was eliminated through combination of reduction in flood release and temporary drawdown in storage, as follows:

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Total Shortfall Flood Reduction Difference Drawdown on 12/31/2004

Volume (TAF) 1,529 854 676 676

Percent of Shortfall 100% 56% 44% 44%

As explained earlier, the temporary drawdown in storage was recovered in 2006, thus presenting no impact on storage in New Melones.

8 CONCLUSIONS
Based the modeling runs that I performed with the NM Model, I have concluded that the USBR had sufficient water in New Melones to serve the Plaintiffs with 155,000 acre-feet each year in the years 1993 through 2004, without diminishing the amounts of water released by the USBR for other purposes, nor the volume of water in New Melones Reservoir as of June 2006. The hydrologic conditions in the period 1993-2004 were 14% higher than the long-term average. New Melones storage volume which started low in 1993 recovered and reached flood control levels by 1996. The reservoir was then full or nearly full for five consecutive years, through 2001. The additional water that could have been served to the Plaintiffs would have been supplied primarily by reduction in flood control spills and secondarily by creating a temporary drawdown in storage that eventually would have recovered in 2006.

Date:

July 26, 2006

_______________________ Avry Dotan, M.S.

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Appendix A Personal Resume

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Qualifications

AVRY DOTAN
Water Resources Consultant
EXPERIENCE SUMMARY Avry Dotan has over 25 years of professional experience in the area of water resources consulting and planning including: conceptual design of dams and hydroelectric power plants, hydraulic and hydrology analysis, permits and licensing, feasibilities studies, project operation, cost estimating and financial analysis. Mr. Dotan has an extensive experience in water resources projects' financing and refinancing, expert witness testimonies, settlement negotiation, headwater benefit analysis, projects appraisal, and due diligence. Mr. Dotan developed and published comprehensive computer programs for optimizing and sizing multi-purpose water and power developments including run-of-river, storage, pumped storage and off-stream storage hydroelectric projects. His models received national recognition by engineering companies, utilities and private developers and have been used in the planning of over 50 projects throughout the United States. Mr. Dotan authored several technical papers on the topic of state-of-the-art technologies in using computers in water and power planning. His work was published in civil engineering journals including CIVIL ENGINEERING and ENR. EDUCATION M.S. B.S. Civil Engineering (1983) - University of Minnesota Civil Engineering (1981) - Technion, Israel Institute of Technology

EMPLOYERS 1990-Present: 1987-1990: 1984-1987: 1982-1983: 1981-1982: CITIZENSHIP Israel, U.S.A. PROJECT EXPERIENCE Stanislaus ­ Lower San Joaquin Water Temperature Modeling and Analysis, California - Independent Consultants. Providing consulting services to CALFED in the implementing the HEC-5Q model to the Stanislaus and the Lower San Joaquin River System. Currently (under contract extension), in the process of implementing it for other tributaries of the San Joaquin River, the Tuolumne and Merced rivers, and to the main-stem San Joaquin River. Stanislaus River Water Temperature Model, California - Independent Consultants. Provided consulting services to a stakeholders group on the Stanislaus River, including: USBR, USFWS, CDFG, OID, SSJID, and SEWD, in developing a water temperature model for the Stanislaus River. The work involved studies for operational changes and physical improvements to exiting facilities to enhance fish habitat conditions for fall-run Chinook salmon and Steelhead rainbow trout. Westpark Litigation, California - Independent Consultant. Providing consulting services and expert witness testimony to Alexander Anolik, A Professional Law Corporation related to the Westpark litigation. The work involved assembling and leading a team of experts in the area of meteorology, hydraulics, hydrology and sediment transport in evaluating the February 24, 2004 rainstorm event and the resulting flood that damaged over 50 homes in the Westpark-Lakeview-Parkside area in Daly City. AD Consultants, Moraga, California Morrison-Knudsen Company, San Francisco, California Tudor Engineering Company, San Francisco, California Saint Anthony Falls Hydraulic Lab., University of Minnesota, Minneapolis, Minnesota TAHAL Consulting Engineering Inc., Israel

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Putah Creek Litigation, California - Independent Consultant. Providing consulting services and expert witness testimony to Solano County Water Agency related to the Putah Creek litigation. The work involved developing computer simulation model of Lake Berryessa and the Putah Creek. Provided services related to the analysis of different proposals of instream flow scenarios on the Putah Creek and simulation of Lake Berryessa operation which resulted in a settlement agreement between the parties involved. Sand Bar Hydroelectric Project Settlement, California - Independent Consultant: Provided an independent assessment of the dependable capacity of the 16.2 MW Sand Bar project on the Middle Fork Stanislaus River, California. Work included the reconstruction of unimpaired flow data in the river basin, the development of sitespecific computer model to simulate the operation of Donnells and Beardsley Reservoirs and Sand Bar power plant and interpretation of licensing, contractual agreements and environmental constraints. Participated in negotiating a settlement between PG&E - the power purchaser and Tri-Dam Power Authority - the owner related to the project dependable capacity. Also provided services to Tri-Dam related to the refinancing of the Sand Bar Project. Headwater Benefits Settlement, California - Independent Consultant. Reviewed FERC's report on headwater benefit determination on the Stanislaus River for the Tulloch Hydroelectric Project. Work included the review of operation scenarios, development of computer operation model of Melones and Tulloch reservoirs, cost analysis and assistance to Tri-Dam Power Authority to reach an early conclusion of a settlement with the FERC. Melones Hydroelectric Project Litigation, California - Independent Consultant: Provided an independent assessment to Pacific Gas & Electric Company of the energy generation from the original PG&E 26 MW Melones Hydroelectric Project on the Stanislaus River in California. The work involved developing computer simulation model of the operation of the Old Melones Reservoir and power plant using detailed performance curves. Results of the model were used in the litigation case associated with the condemnation of the original Melones power plant by the federal government. EBMUDSIM: Efficiency Improvements, California - Independent Consultant. Provided consulting services to East Bay Municipal Utility District in implementing efficiency improvements to their water supply planning computer simulation model EBMUDSIM. The work involved re-coding of the model using object oriented technology approach, enhancing the model to simulate future project configurations and modes of operation, developing user's interface and providing staff training with the model. PG&E Hydroelectric System on the Mokelumne River, California - Independent Consultants. Provided consulting services to East Bay Municipal Utility District (EBMUD) in analyzing the operation of two reservoirs and four power plants owned by PG&E upstream to the EBMUD water supply system. The work involved the development of computer simulation model of the hydroelectric system and operations studies for assessing the potential benefits from acquiring the PG&E facilities on the Mokelumne River. Pardee Reservoir Enlargement Project, California - Independent Consultant. Providing consulting services to East Bay Municipal Utility District related to the enlargement of the existing Pardee Dam and Reservoir. The work involves operations studies of the EBMUD's water supply and hydroelectric system on the Mokelumne River with raised Pardee Dam and alternative sites for a new Dam. Boulder Valley Pumped Storage Project, California - Independent Consultant: Provided consulting services to Consolidated Pumped Storage Project, Idaho, in the development of 515 MW pumped storage project near San Vicente Reservoir, San Diego, California. His work involved screening analysis of selected alternatives and preparation of supporting data for Agency Consultation. He assisted Duke Engineers & Services in the development of cost estimates using Pumped storage Cost Model (PCM) that he developed. The work included also preliminary cost estimates for two RCC dams for upper reservoir sites. Garden Bar Pumped Storage Project, California - Independent Consultant: In charge of the analysis of the operation of the proposed 220 MW hybrid conventional and pumped storage hydroelectric project on the Bear River in Northern California. Work included the development of operations model to simulate the operation of the Garden Bar Project in conjunction with the operation of other water and power facilities on the River. Assisted Consolidated Pumped Storage, Inc. in determining the optimum project configuration and the integration of this project in the resource plan of utilities in the region.
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Qualifications

Pumped Storage Evaluation in Northern California, California - Independent Consultant: Performed cost estimates and screening analysis of potential pumped storage sites in Northern California. Work included the use of Pumpedstorage Cost Model (PCM) to develop construction costs of alternatives and ranking of alternatives on a minimum cost per kW basis. River Mountain Pumped Storage Project, Arkansas - Independent Consultant: In charge of the development of a comprehensive hydraulic model to simulate the operation of the proposed 600 MW pumped storage project, two lock and dams and two hydroelectric power plants on Lake Dardanelle, Arkansas. The model was used by the developer, Consolidated Pumped Storage, Inc., to evaluate the potential effects of project operation on navigation and power plants operation on the lake. The model also provided the basis for an Operating Agreement between the developer, the Southwestern Power Administration and the U.S Army Corps of Engineers. Clavey River Hydroelectric Project, California - Independent Consultant: Assisting with the preparation of the FERC License Application for this 150 MW hydroelectric project. Work includes hydrology analysis, economic evaluation, operation studies, computer modeling of reservoir operation in conjunction with environmental concerns, power plant operation, Need for Power analysis, agencies consultation and public information programs. Re-licensing of Small Hydroelectric Projects in Southern California, California - Independent Consultant: Provided services to SCE related to the re-licensing of several run-of-river hydroelectric projects on Lytle Creek, Mill Creek and Santa Ana River in Southern California. Work included hydrological analysis and operation studies related to instream flow scenarios. Goodwin Hydroelectric Project, California - Independent Consultant: Involved in the preparation of the FERC license application for this 5 MW hydroelectric project. Work included conceptual design, hydrology analysis, simulation of power plant operation, cost estimate and financial analysis. Muck Valley Hydroelectric Project, California - Independent Consultant: Performed operation studies to analyze the performance of the 30 MW Muck Valley Project. Work included the development of long-term hydrological data, power studies and dependable capacity evaluation obtained from off-stream storage reservoir situated at Collett Lake. Upper American River Project (UARP), California - Independent Consultant: Provided consulting services related to the upgrade of the existing simulation model of the UARP system. Tasks included optimization routines and firm capacity and energy analysis of the existing system and of potential developments in the basin. Twin Springs Reservoir and Hydroelectric Project, Idaho - Project Manager/Engineer: In charge of the preparation of FERC Preliminary Permit Application and feasibility studies for this hydroelectric project. Project consists of 450 feet high RCC dam, 600,000 Acre-ft reservoir and 100 MW power plant. Responsible for obtaining FERC permits, agencies consultation, optimization analysis of reservoir size and power plant capacity. Developed models to simulate project operation to meet irrigation demand, flood control, water quality requirements and recreational activities in the entire Boise River Basin. Arrowrock Hydroelectric Project, Idaho - Project Engineer: In charge of the conceptual design and the final configuration of this project. Project consists of 65 MW power plant at the base of the existing Arrowrock Dam on the Boise River. Work included optimization analysis of turbine type and capacity, simulation of power plant operation, cost estimate and financial analysis. Milner Hydroelectric Project, Idaho - Senior Engineer: Analyzed the final configuration of this 68