ARIZONA WATER BANKING AUTHORITY ANNUAL PLAN OF OPERATION 2002 Joseph C. Smith, Chairman December 2001 INTRODUCTION The Arizona Water Banking Authority (AWBA) was created to store Arizona’s unused Colorado River water entitlement in western, central and southern Arizona to develop long-term storage credits to: (1) firm existing water supplies for municipal and industrial users (M&I) along the Colorado River and Central Arizona Project (CAP) M&I users during Colorado River shortages or CAP service interruptions; (2) help meet the water management objectives of the Groundwater Code; and (3) assist in the settlement of American Indian water rights claims. Changes in the AWBA’s enabling legislation in 1999 authorized the AWBA to participate in other water banking activities, however, no new water banking activities are included in this annual Plan of Operation. The AWBA’s storage (or banking) of water is accomplished through the Underground Water Storage, Savings and Replenishment Act (UWS) enacted by the Arizona legislature in 1994 and administered by the Arizona Department of Water Resources (ADWR). Through this program, the AWBA stores renewable water that currently has no immediate, direct use in either underground storage (USF) or groundwater savings (GSF) facilities. A USF is a facility that allows water to physically be added to an aquifer. A GSF is a facility where the renewable water is used in place of groundwater, creating a groundwater savings. The UWS program mandates the accounting of the renewable water stored and the development of long-term storage credits. The longterm storage credits developed by the AWBA will then be utilized by the AWBA when future conditions warrant. The use of credits for the three objectives listed above may differ and is dependent on the source of funds utilized to develop them. The AWBA is required by statute to approve an annual Plan of Operation (Plan) by January 1 of each year. Prior to approval of the final Plan, the AWBA is required to solicit public comment. This is achieved by presenting a draft of the Plan to the Groundwater Users Advisory Councils (GUAC) for the Phoenix, Pinal and Tucson Active Management Areas (AMA) and to the county board of supervisors for counties outside of the AMA’s if water storage is proposed there within the Plan. Presentation of the draft Plan must be made at publicly noticed open meetings at which members of the public are permitted to provide comment. The AWBA also accepts public comment in writing up to the time the final draft Plan is presented for approval. This Plan does not include an interstate water banking component. When it is anticipated that the final approved Plan may include an interstate water banking component, pursuant to the provisions of the Agreement for Interstate Water Banking, the initial draft Plan will not. Not including the interstate water banking component in the initial draft Plan allows the AWBA to insure that Arizona’s water banking interests have been met prior to inclusion of an interstate banking component. On or before November 1, the AWBA will advise the Nevada entities of any opportunity for interstate water banking. They will, in turn, advise the AWBA of their desire to accept or decline the amount offered. Consequently, absence of an interstate component in a draft Plan does not indicate that interstate water banking will not occur. The Plan is intended to govern the operations of the AWBA over the course of the entire calendar year. During the course of the year, changing circumstances may present limitations or provide new opportunities not contemplated in the adopted Plan, 1 which could affect the overall delivery projections. In such circumstances, the AWBA may choose to modify its adopted Plan. If such modifications are required, the proposed modifications will be discussed and, if acceptable, approved at a public meeting of the AWBA and an Amended Plan will be prepared. The AWBA recognizes that day-to-day adjustments in the normal operations of the CAP or the individual storage facilities caused by maintenance and fluctuations in the weather may affect the actual monthly deliveries made on behalf of the AWBA. If the adjustments do not impact the overall annual delivery projections contained in the Plan, they will not be deemed modifications to the Plan and will be addressed by staff and reported to the AWBA members on an as-needed basis. 2001 PLAN OF OPERATION In 2001, the AWBA’s fifth full year of operation, the AWBA recharged more than 295,000 acre feet of Colorado River water and Arizona’s total use of Colorado River water was forecast to be 2.66 million acre feet. Consequently, the AWBA continues to play a role in bringing Arizona closer to full utilization of their normal year entitlement of 2.8 million acre feet (see Figure 1). ARIZONA USES (Million Acre Feet) Diversion 3.00 0.25 0.29 0.30 1.19 1.21 1.16 1.14 1.13 1.20 2.00 1.00 0.00 1999 2000 2001 Year CAP OTHER BANK Figure 1 Because the Secretary of the Interior declared that the Colorado River was in limited surplus in 2001, Arizona’s use did not impact the other Lower Basin states' uses. Total use of Colorado River water in the Lower Basin is forecast to be approximately 8.15 million acre feet in 2001 (see Figure 2) based on Bureau of Reclamation data dated November 29, 2001. 2 LOWER BASIN USES (Million Acre Feet) Diversion 9.00 0.29 0.32 0.32 6.00 2.58 2.63 2.66 3.00 5.11 5.07 5.17 0.00 1999 2000 2001 Year CALIFORNIA ARIZONA NEVADA Figure 2 The AWBA recharged water at both USFs and GSFs in 2001. Table 1 lists the AWBA's recharge partners for 2001, the amount of water that can be stored under each AWBA water storage permit, and the amount of water delivered to the facility by the AWBA in 2001. Table 1 values are based on actual deliveries through November with December’s deliveries estimated. The amount of water delivered to a facility is always greater than the amount of long-term storage credits earned by the AWBA because credits are computed by subtracting approximately 3-5% for losses and 5% for a "cut to the aquifer" from the total annual deliveries. Final figures for credits earned generally become available in the middle of the following year after review of the annual reports filed with the ADWR and are reported in the AWBA’s Annual Report. Table 1 AMA Phoenix Pinal Tucson Facility GRUSP Agua Fria Chandler Hts Citrus ID Queen Creek ID New Magma IDD SRP MSIDD CAIDD Hohokam ID Avra Valley (CAP) Lower Santa Cruz (CAP) Pima Mine Road (CAP) Kai-Red Rock Type Permit Capacity Amount Delivered USF USF GSF GSF GSF GSF GSF GSF GSF USF USF USF GSF 200,000 AF 100,000 AF 3,000 AF 28,000 AF 54,000 AF 200,000 AF 120,000 AF 110,000 AF 55,000 AF 11,000 AF 30,000 AF 30,000 AF 11,231 AF 62,702 AF 4,464 AF 545 AF 8,829 AF 44,162 AF 14,935 AF 48,145 AF 12,141 AF 54,936 AF 6,141 AF 24,299 AF 12,973 AF 863 AF Total 952,231 AF 3 295,135 AF The 2001 Plan scheduled more than 319,000 acre feet of water to be delivered for recharge around the state. The amount of water actually delivered amounted to slightly more than 295,000 acre feet. Reduced availability at two facilities accounted for the majority of the difference between projected and actual deliveries. There was a curtailment of storage at the Granite Reef Underground Storage Project pursuant to the provisions of Salt River Project’s agreement with the Salt River Pima Maricopa Indian Community. There was also a reduction in the storage at the Agua Fria Recharge Facility as the available storage was utilized by the Central Arizona Groundwater Replenishment District to meet their replenishment obligations. The historical trend of a greater amount of storage at GSF’s continued in 2001. Figure 3 shows the acre foot break down between GSFs and USFs for 2001 and a comparison between 2001 and previous years. RECHARGE BY TYPE (Million Acre Feet) Deliveries 0.30 0.08 0.12 0.11 0.17 0.19 0.20 0.17 0.10 0.00 1999 2000 2001 Year GROUNDWATER SAVINGS UNDERGROUND STORAGE Figure 3 2002 PLAN OF OPERATION When developing the 2002 Plan, the AWBA evaluated four critical factors: (1) the amount of unused water available to the AWBA for delivery, (2) the CAP capacity available to the AWBA for the delivery of unused water, (3) the funds available and the costs required to deliver the unused water, and (4) the capacity available for use by the AWBA at the various recharge facilities. The Bureau of Reclamation published the Annual Operating Plan (AOP) for water year 2002 on October 15, 2001. The 2002 AOP prescribes that a full domestic surplus condition will govern releases from Lake Mead for the Lower Basin states in 2002. This surplus condition is described in the Interim Surplus Guidelines that became effective on February 26, 2001 and, in effect, limits Arizona to 2.8 million acre feet. Based on the Secretarial declaration and proposed uses, the overall Lower Basin use is projected to be 8.15 million acre feet (Figure 4) and Arizona’s use is forecast to be 2.75 million acre feet (Figure 5). Consequently, water availability will not be a limiting factor for the AWBA in 2002. 4 2002 LOWER BASIN USES (Million Acre Feet) 0.32 5.08 2.75 ARIZONA CALIFORNIA NEVADA Figure 4 2002 ARIZONA USES (Million Acre Feet) 0.35 1.17 1.23 OTHER CAP BANK Figure 5 The CAP 2002 Operating Plan would accomodate the delivery of approximately 1.65 million acre feet of water. CAP's plan delivers approximately 1.17 million acre feet to its subcontractors, leaving 480,000 acre feet of capacity available for the AWBA. Based on this available capacity, the CAP’s operations will not be a limiting factor for the AWBA in 2002. The funding available to the AWBA from its three sources (county ad valorem property tax revenues, groundwater pumping fees, and general funds) to pay for the delivery of water in 2002 will be approximately $49 million including the carryover from previous years. Given the costs associated with the delivery of water and the continued policy of GSF operators paying $21 of the water delivery costs to their facilities, the $49 million is adequate to fund the Plan and is not a limiting factor in 2002. For more information about the cost of the Plan, please refer to the pricing section. To assist in developing the 2002 Plan, facility operators submitted an annual delivery schedule to the CAP that included their projected storage with the AWBA. The CAP schedules the AWBA's deliveries to the USFs it operates. The CAP staff utilized the facility operator’s schedules to compile an annual schedule for the CAP, including 5 municipal and industrial (M&I) water, water for Indian tribes, incentive recharge water, agricultural pool water, and AWBA water. Concurrently, the AWBA staff met with the facility operators to discuss their delivery schedules and development of new facility agreements as appropriate and confirm their continued interest in participating with the AWBA. These discussions confirmed the availability of substantial permitted recharge capacity but also that not all of the existing capacity is available to the AWBA. Some of the GSF availability was limited by delivery cost and operational constraints or previous commitments to other partners limited the availability of both the GSFs and the USFs to the AWBA. Accordingly, the only constraint on AWBA storage in 2002 is availability of recharge facilities. The CAP water that the AWBA purchases from CAWCD can be viewed as having two components, cost and availability. The pricing aspect of the water deliveries is discussed further in the pricing section of this document. With regard to availability of water, the AWBA purchases water from the category that is termed excess water. Excess water is generally recognized to be all water available for delivery through the CAP, regardless of Secretarial declaration of condition, that exceeds the quantities scheduled under long-term contracts and subcontracts. The availability of excess water is determined on an annual basis. In 2002, and until 2004, there are no pools associated with excess water and the AWBA has available to it any water not requested by another entity within Arizona. In light of the Repayment Settlement Stipulation with the federal government, the CAWCD has proposed a new policy for excess water that will become effective in 2004 and continue until 2030. This policy establishes eligibility criteria, priority and price for each pool or category. The AWBA category is established exclusively for the AWBA’s intrastate storage purposes. Size and price of the pool will be established by the CAWCD Board; a priority was not established for this pool. This policy also establishes an Interstate Storage category for the AWBA’s interstate storage purposes. The price for water delivered for interstate banking will be established according to statute. This pool strategy has been discussed in numerous CAWCD Board meetings but has not yet been officially adopted as Board policy. The AWBA anticipates recharging more than 350,000 acre feet of Colorado River water in 2002. The 2002 Plan was developed utilizing permitted facilities located in Maricopa, Pinal and Pima Counties and attempts to optimize, on a monthly basis, the delivery of Colorado River water to meet the AWBA's objectives. The Plan is flexible and if additional recharge capacity can be identified and funding remains available it can be modified in the future to include additional facilities. Table 2 shows the AWBA's 2002 delivery schedule. Line One of this table provides estimates of the CAP's monthly deliveries to its M&I, agricultural, incentive recharge, and Indian customers. These deliveries have a scheduling priority over the AWBA’s deliveries. These estimates do not include deliveries to New Waddell Dam. Line Two shows the operational capacity of the CAP available after it makes its priority deliveries and its deliveries to New Waddell Dam. Although the CAP is capable of delivering approximately 180,000 acre feet per month, the available capacity does not always total that because of unique situations. These can include the filling of Lake Pleasant in the winter months, deliveries to the western portion of the aqueduct, New 6 1 AWBA -- Recharge Sites : USF PHOENIX A M A : GSF GRUSP HIEROGLYPHIC MTN. AGUA FRIA CHCID NEW MAGMA QUEEN CREEK SRP TONOPAH ID PINAL A M A : ARIZONA Table 2 2001 BANKING AUTHORITY Water Delivery Schedule (AF) Deliveries WATER Calendar Year 2 0 0 2 17,000 22,000 49,000 Feb 4,800 0 2,033 50 3,200 0 1,600 0 26,000 110,000 Mar 0 6,500 620 4,800 0 5,600 100 2,500 0 1,600 0 48,000 118,000 Apr 570 2,600 2,600 0 36,240 0 10,000 4,870 4,800 0 6,100 100 3,000 0 1,600 0 47,000 135,000 May 570 2,600 2,600 0 39,621 0 8,000 10,700 3,800 0 6,100 151 3,500 0 1,600 0 54,000 165,000 Jun 570 2,100 1,661 0 30,016 0 4,000 6,010 3,800 0 6,450 125 3,700 0 1,600 0 40,000 570 2,600 1,742 500 44,258 3,000 7,600 210 3,800 0 7,100 125 9,700 5,711 1,600 0 58,000 185,000 145,000 570 230 2,000 400 1,293 972 500 0 40,470 20,375 7,000 3,500 200 3,800 0 7,100 125 9,600 3,182 1,600 0 3,800 0 5,100 191 3,500 1,682 0 0 50,000 53,000 70,000 69,000 Sep 2,500 2,000 0 570 1,131 2,600 0 25,092 1,000 1,000 710 3,800 3,000 5,579 0 2,500 1,202 0 2,000 Nov 1,500 1,500 2,140 3,800 3,000 7,100 0 2,000 1,723 0 1,000 36,000 29,000 42,000 570 2,600 2,600 0 29,533 15,000 54,500 27,830 50,600 6,000 62,329 1,117 47,200 13,500 11,200 3,000 480,000 40,000 1,173,000 Dec 6,500 25,431 25,468 1,000 350,675 6,141 12,973 24,299 863 295,135 12,141 54,936 48,145 62,702 0 4,464 545 44,162 8,829 14,935 0 Total 4,800 0 2,034 100 2,000 0 0 0 0 6,400 1,350 570 2,100 2,600 0 26,990 Oct 4,800 0 2,033 50 2,000 0 0 0 0 2,500 510 570 2,600 2,600 0 25,203 Aug 50,600 6,000 62,329 1,117 47,200 13,500 11,200 3,000 0 1,500 510 570 2,600 2,600 0 17,714 Jul (ACRE-FEET) 200,000 35,0001 100,000 3,000 54,000 28,000 200,000 15,000 15,000 54,500 27,830 570 2,100 1,600 0 15,163 Jan 110,000 55,000 120,000 6,500 25,431 25,468 1,000 350,675 Permitted Requested Capacity Capacity (AF) (AF) 1,837 4,286 797 21,010 10,760 14,379 9,984 13,742 9,530 32,625 10,908 (533) 129,325 Estimated CAP Deliveries + Losses : 45,000 (M&I, Indian, Ag Pools 1 , 2 & 3, Incentive Recharge) 11,000 30,000 30,000 11,231 2 Available Excess CAP Capacity for AWBA : 3 4 5 6 7 8 9 10 Remaining CAP Capacity : 11 GSF CAIDD 12 HOHOKAM 13 MSIDD TUCSON A M A : USF AVRA VALLEY PIMA MINE ROAD LOWER SANTA CRUZ KAI – RED ROCK T O T A L (USF + GSF) : 14 15 16 17 18 19 1 The Hieroglyphic Mountain Recharge Project has not yet been permitted. The application was for 35,000 acre feet per annum and it is anticipated that the AWBA will apply for a water storage permit in the same amount. Waddell Dam releases to the aqueduct in the summer months and scheduled maintenance and outages. During the fall and winter months, the capacity available to the AWBA is constrained because the CAP is making deliveries to Lake Pleasant. Lines Three through Seventeen represent the AWBA’s 2002 Plan of Operation. This section identifies the AWBA’s partners for 2002 and the amount of water scheduled to be recharged. The second column in this section identifies the AWBA’s water storage permit capacities for each facility based on the facility permits and the amount of that capacity that is available to the AWBA in 2002. The capacity available does not always equal the storage permit capacity because the storage facility operators may have agreements with other storage partners. Line Eighteen lists the total amount of AWBA storage scheduled for the year 2002. and Figure 6 illustrates the distribution of that amount between GSFs and USFs. For the first time since the AWBA’s inception, storage at USFs and GSFs will be approximately equal. 2002 RECHARGE BY TYPE (Million Acre Feet) 0.18 0.17 GROUNDWATER SAVINGS UNDERGROUND STORAGE Figure 6 Line Nineteen lists the CAP capacity remaining after the AWBA’s deliveries are scheduled. The CAP has shown in the past that there is some operational flexibility to help meet deliveries in any given month. The AWBA staff will work closely with the CAP staff and our partners in an attempt to meet all scheduled deliveries. No recovery is anticipated in 2002. The AWBA will continue to work with CAWCD to pursue recovery concepts in 2002 and beyond. NEW FACILITIES In 2002, the Plan anticipates recharging water at only one new facility, the Hieroglyphic Mountains Recharge Project (HMRP). CAWCD is developing the HMRP as a Maricopa County State Demonstration Project. The HMRP is located near 163rd Avenue and Dixileta Road within the Phoenix Active Management Area. As proposed, it will include 7 three infiltration basins covering 50 acres with a storage capacity of 35,000 acre feet per annum. The recharge project is uniquely located adjacent to the CAP canal and upstream of the Waddell Canal. The HMRP has not yet obtained a facility permit from the ADWR, however, the public notice of the application has been completed. CAWCD projects facility construction to begin in February 2002 with recharge activity commencing in October 2002. INTERSTATE WATER BANKING On July 3, 2001, the final Agreement for Interstate Water Banking (AIWB) was signed by Arizona and Nevada at a formal signing ceremony in Las Vegas. While this agreement was fully executed, the AWBA is not required to store water for Nevada until two additional agreements are executed. The other two agreements necessary to initiate interstate water banking are the Storage and Interstate Release Agreement (SIRA) and the Agreement for the Development of Intentionally Created Unused Apportionment. These agreements are being developed on the basis of concepts agreed upon in the AIWB, with the SIRA being the current agreement of focus. The negotiating team continues to work on the SIRA in conjunction with Nevada and representatives of the Bureau of Reclamation. It is projected that the remaining agreements will be executed in the spring of 2002. Consequently, the earliest that initiation of interstate storage would likely be addressed by the AWBA would be the June 2002 meeting. Amendment of this Plan would be required prior to commencement of any interstate water storage. PRICING On June 21, 2001, the CAWCD board adopted final water delivery rates for 2002. The rate for AWBA and other M&I Incentive recharge will be $55 per acre foot. The delivery rate is the pumping energy rate 2 component ($49 per acre foot) plus 10 percent of the fixed OM&R charge ($3.30 per acre foot) plus a component to recover lost revenues from federal deliveries ($2.24 per acre foot). The components of the rate are the same as those in the 2000 and 2001 rates. For 2002, the pumping energy rate 2 was calculated using the average of the above threshold energy rates for the previous three years. The AWBA’s policy of recovering $21 from its groundwater savings facility partners will continue for 2002. Table 3 reflects the water delivery rate the CAP will charge the AWBA, the rate the GSF operators will pay for use of the AWBA’s water and the various rates the AWBA will be charged to utilize the different USFs. 8 Table 3 2002 Water and Facility Rates – Intrastate CAP’s delivery rate to AWBA $55 per acre foot Groundwater Savings Facility operator portion of delivery rate $21 per acre foot 1 Underground Storage Facility rate paid by AWBA 1 GRUSP (SRP) $17.52 per acre foot Avra Valley (CAP) $23.54 per acre foot Hieroglyphic Mtns. (CAP) $7.90 per acre foot Pima Mine Road (CAP) $5.97 per acre foot Lower Santa Cruz (CAP/Pima County) $12.44 per acre foot Agua Fria Recharge Project (CAP) $3.68 per acre foot This rate is paid directly to CAP by the GSF operators and is not available as revenue to the AWBA. The AWBA’s rate for delivery of in lieu water is thus reduced to $34/af. The individual USF agreements determine the cost components paid by the AWBA. For GRUSP, the cost is comprised of an annual administration component, a component for use of the SRP interconnection facility, a transportation component and a general facility component. The other five USFs utilized in the Plan are operated by the CAP and were constructed using state demonstration project funds. Therefore, the CAP does not charge the AWBA a capital cost component for the facilities. Also, there is no administration cost component included in the facility cost because the AWBA pays the CAP administrative costs on an annual basis. The Avra Valley facility has an operation and maintenance (O&M) component, a land lease charge component and a wheeling component for use of the BKW water delivery system. The Lower Santa Cruz has an O&M component and a wheeling component for use of the same system. The Pima Mine Road and Agua Fria facilities have O&M components. The Hieroglyphic Mountains facility charge is only an estimate as there is currently no agreement for storage at the facility. The CAP facility O&M component typically includes facility maintenance and repair, monitoring, water quality sampling and data management and reporting. The estimated total cost of the AWBA’s 2002 Plan of Operation is approximately $17 million which includes the USF use fees and the CAP delivery rate minus cost recovery from the GSF operator by the CAWCD. ACCOUNTING The AWBA’s enabling legislation required the development of an accounting system that allows the tracking of all long-term storage credits accrued by the AWBA and 9 the funding sources from which they were developed. The ADWR has established accounts that track both credits and funds. Table 4 provides estimates of the funds available including funds carried over from previous years and an estimate of funds to be collected during the year, the funds to be expended, and the credits that will accrue to those accounts based on the 2002 Plan. Table 4 2002 PLAN OF OPERATION 1 FUNDING AVAILABLE EXPENDED 2 CREDITS AMOUNT LOCATION Withdrawal Fee Phoenix AMA Tucson AMA Pinal AMA $12,333,117 $3,481,180 $1,548,649 $0 $0 $1,548,632 0 0 41,000 Phoenix AMA Tucson AMA Pinal AMA Four Cent Tax Maricopa County Pima County Pinal County $23,553,694 $6,212,907 $280,000 $10,241,556 $3,293,189 $279,990 175,000 AF 45,000 AF 7,000 AF Phoenix AMA Tucson AMA Pinal AMA $2,000,000 $2,000,008 $0 $519,410 $1,480,598 46,000 AF 0 AF 7,000 AF 39,000 AF Phoenix AMA Tucson AMA Pinal AMA Other General Fund California Nevada TOTAL (not applicable) (not applicable) $49,409,547 $17,363,376 314,000 AF 1 Does not include groundwater savings facility partners' payment. The AWBA’s partners make payments directly to the CAWCD. 2 Estimate based on 89.78% of the deliveries. Table 5 provides an estimate of the funds expended and the credits that will accrue to various accounts based on the AWBA’s recharge activities since its inception. 10 Table 5 CUMULATIVE TOTALS 1997-2001 1 EXPENDED Withdrawal Fee Phoenix AMA Tucson AMA Pinal AMA Four Cent Tax Maricopa County Pima County Pinal County Other General Fund CREDITS AMOUNT LOCATION $0 $0 $3,751,010 0 0 144,231 Phoenix AMA Tucson AMA Pinal AMA $23,964,843 $3,488,614 $1,390,893 608,692 AF 59,179 AF 64,002 AF Phoenix AMA Tucson AMA Pinal AMA $10,695,000 $2,146,252 $5,361,381 $3,187,367 375,773 AF 58,173 AF 265,209 AF 52,391 Phoenix AMA Pinal AMA Tucson AMA $43,290,360 1,251,877 AF California Nevada TOTAL 1 Actual credits used for 1997,1998,1999 and 2000; credits estimated for 2001 PUBLIC REVIEW AND COMMENT The AWBA staff held public meetings in conjunction with the GUACs for the Phoenix, Pinal and Tucson AMAs as required by the AWBA’s enabling legislation. Phoenix GUAC There was discussion and questions regarding the Secretary’s declaration for the Colorado River and the new Interim Surplus Guidelines. The GUAC expressed its concern regarding the possible decrease in, or loss of, the AWBA’s $2 million general fund appropriation in light of the current budget crisis. The GUAC stated they felt that the legislature needed to be informed of the importance of the AWBA’s function and M&I firming and would be willing to help carry that message to the governor and the legislature. There was discussion regarding the costs associated with GSF versus USF storage and a question regarding the funding source for the Hieroglyphic Mountain 11 Recharge Project. In general, the GUAC supported the Plan and had no requests for additions to, or modification of, it. Pinal GUAC There were no specific comments regarding the Plan or requests for modification. Tucson GUAC There was general discussion regarding the status of interstate negotiations with California, the manner in which GSFs operate and development of a recovery plan. With regard to this Plan, there was a question whether more water could somehow be recharged in the state or in the Tucson AMA in 2002 when the price for CAP water is lower than forecast for 2003 and 2004. The current limitations for storage were described. The GUAC expressed its support of the plan with the caveat that there were some concerns regarding interstate water banking. The GUAC expressed their support in a letter to the AWBA. General Public Letters were received from staff at the Central Arizona Project and the president of the Southern Arizona Water Users Association. 12