ITEM:            ACTION ITEMS

16.                   DISCUSSION OF NEAR TERM WATER SUPPLY CONCEPTS, INCLUDING RECLAMATION

Meeting Date:           February 19, 2004                  Budgeted:  N/A

Program/Line Item No.:  N/A

Staff Contacts:           Henrietta Stern                      Cost Estimate:  N/A

Darby Fuerst

General Counsel Approval: Staff note provided for review

Committee Recommendation: PAC/TAC had no recommendation on January 28, 2004

CEQA Compliance: Not needed for discussion; CEQA needed for new projects

# Ø      Pebble Beach Wastewater Reclamation Project—MPWMD share;

Ø      Paralta well community drought reserve;

Ø      Conservation savings;

Ø      Aquifer storage and recovery (ASR) in Seaside Basin;

Ø      In-lieu recharge in Seaside Basin

This item is continued from the January 29, 2004 meeting (Item 18) due to time constraints.

# The Board should focus on the sections near the end of this staff note titled, “Overall Summary and Concepts for Consideration” and “Specific Allocation Concepts.”  The Board may wish to provide direction on the process used to determine answers to the above questions, such as review by various committees and when recommendations to the Board should be submitted.

BACKGROUND AND DISCUSSION:  The following text addresses potential sources of supply that have been suggested to be pursued in the immediate future.  This agenda item originally focused on reclamation, but has been expanded to review other concepts and potential courses of action for consideration.

Overview of Water Sources Thought To Be Available

It must be stressed that SWRCB Order 95-10 sets established Cal-Am production limits from the Carmel River system that are not likely to change for many years.  More importantly, the one-for-one replacement component of the Order requires that any new source of supply be used to offset pumping from the Carmel River until the entire unlawful amount (estimated at 10,730 acre-feet) is replaced; no portion of the new water may be used for new construction and remodels.  Any water augmentation concept must be consistent with Order 95-10.  In addition, litigation over the Seaside Basin will likely result in Court-ordered limits to production; it is unknown whether these limits will be the same or less than today’s limits imposed by MPWMD.  Given recent hydrologic trends, it is unlikely that production limits will increase unless there is a successful recharge program or other means to reverse the declining water levels.

Another important point is that the conceptual “sources of water” suggested by various parties are not actual physical sources of water.  There appears to be a misconception that water is actually being withheld and stored in some undisclosed location, and needs to be released.  This is not accurate.  Unless noted otherwise, all sources of water described below are already part of the Cal-Am system that draws from the Carmel River and Seaside Basins.  Water may have been available from certain Cal-Am system components in the past, but is not legally (or in some cases, physically) available today.

Pebble Beach Wastewater Reclamation Project—Benefited Properties (380 AF)

Up to 380 acre-feet annually (AFA) of Cal-Am water for designated “benefited properties” within the Del Monte Forest are acknowledged by the SWRCB to be additive to the 11,285 AF interim diversion limit as new properties are served. This quantity was based on the assumption that the Reclamation Project would replace 800 AFA of potable Cal-Am supply used to irrigate turf on golf courses and sports field within Del Monte Forest.  It is important to note that the goal is not simply to produce 800 AFA of reclaimed water.  Rather, the goal is to enable replacement of 800 AFA of Cal-Am potable water; that is, to reduce the need for the irrigators to apply Cal-Am water, resulting in close to zero use.  This distinction is important, because if the reclamation plant is producing close to 800 AFA, but potable Cal-Am water is still being applied to turf, the net benefits are reduced by the quantity of Cal-Am use (see below).   Calculations on how well the project is performing should be based on how well Cal-Am water use is minimized rather than the total reclaimed water production of the plant.  Obviously, increasing reclaimed water production is an important factor in reducing Cal-Am use.

Since 1996, the average reclamation plant production has been about 680 AFA of reclaimed water.  Limited production is due to a combination of factors, including weather (need less irrigation water in rainy years), storage limitations (reduces ability to supply water in summer peak demand periods) and water quality concerns (sodium in the reclaimed water harms the greens and tees as it collects in the root zone).  More importantly, the average Cal-Am potable water application in this same period was about 280 AFA.  This water was used to flush the sodium from the root zone under the greens as well as make up for supply shortfalls in summer.

As noted above, the key factor to assessing performance is to calculate the net savings in potable Cal-Am water used.  A key assumption (which may or may not hold true each year) is that 800 AFA of water are needed, on average, to irrigate turf in the project area.  The number of acre-feet of Cal-Am water replaced is compared without and with the reclamation project, as follows:

Pre-project:      800 AFA estimated average Cal-Am water applied to turf;

Post-project:    280 AFA average Cal-Am water actually applied to turf;

Net Savings:     520 AFA average Cal-Am water that is no longer used on turf.

A Phase 2 project is proposed to facilitate increased reclaimed water use, and thereby reduce the need to irrigate turf in the project area with Cal-Am water.  The project entails over $20 million to retrofit a storage reservoir and construct advanced treatment facilities to more efficiently use the reclaimed water and reduce the need to apply Cal-Am water. The MPWMD, in coordination with the Carmel Area Wastewater District, Pebble Beach Community Services District, Pebble Beach Company, and other reclaimed water users, are developing agreements to facilitate financing of the Phase 2 project. MPWMD Ordinance No. 109 addresses the project financing as well as release of a portion of the 380 AFA for additional properties within the Del Monte Forest. Ordinance No. 109 is scheduled for Board consideration on March 15, 2004, along with negotiated “deal points.” Pebble Beach Wastewater Reclamation Project—MPWMD Share (420 AF) In addition to the 380 AF described above, the original reclamation project included a 420 AF share for MPWMD to use at its discretion, assuming reliable replacement of 800 AFA of Cal-Am potable water with reclaimed water. Importantly, the 420 AF is not recognized by the SWRCB as a source of supply to add to the 11,285 AF interim diversion limit. As noted above, the project has been replacing an average of about 520 AFA of Cal-Am supply to date, which is 280 AFA short of the 800 AFA replacement goal. Based solely on Reclamation Project performance, District staff believes it would not be prudent to consider release of any more than 140 AF of the 420 AF District share at this time (420 – 280 = 140). Notably, in August 1996, the District approved Ordinance No. 84 to release 150 AF of the 420 AF. The ordinance was rescinded due to litigation filed against the District because Ordinance No. 84 was approved without an EIR. In order for the District to approve “release” of Cal-Am water as a portion of the 420 AF, an EIR would need to be prepared, and Cal-Am Carmel River diversions must not exceed 11,285 AFA. There is uncertainty whether release of any portion of the 420 AF would be challenged unless the Reclamation Project was producing 800 AFA reliably and Cal-Am water application on the golf courses was closer to zero. Recall that Cal-Am supplies water for new construction and remodels from Carmel River and Seaside Basin sources. Reclaimed water can only be used for irrigation, and is not considered to be a source of domestic potable supply. Release of Community Drought Reserve from Paralta Well (385 AF) In 1993, when allocations from the Paralta well were approved, 385 AFA of production were set as aside as a “community drought reserve.” It has been suggested to tap some of this “set aside production” to provide additional allocations to jurisdictions. Unfortunately, this is not possible for several reasons. First, though the term “drought reserve” gives the impression that a portion of the annual production from the Paralta well was held back, this is not accurate. The “drought reserve’ actually refers to production from the Carmel River that was not being pumped due to the existence of the Paralta well. In reality, the Paralta well produces water at the maximum rate that can be treated at Cal-Am’s Seaside Ozone Treatment Plant. The Paralta well was initially estimated to produce 1,000 AFA of firm yield. Actual production has exceeded this estimate, and in this sense, the 385 AFA “reserve” has already been tapped to meet current demand and stay below the SWRCB limits in Carmel Valley. Thus, no additional supply is available from the Paralta well based on expanding its production capability. Second, even if additional production capacity were available, existing limitations in the Cal-Am distribution system would likely further restrict additional water volume from being transported to customers. Cal-Am investment in its Seaside Basin infrastructure is needed to facilitate greater pumping capacity. Third, even if there were no physical limitations on pumping capacity, the current hydrologic and legal situation in the Seaside Basin would likely constrain how much water may be produced at or near the Paralta well site (which is where the greatest impacts occur) in order to not exacerbate the trend of declining water levels. Recall that production is over or near the estimated 4,375 AFA safe yield estimate for the Coastal Subareas. Fourth, a new well in a location other than the Paralta area would be a likely means to reduce existing adverse effects, but may not increase reliable yield. A new source of supply, however, triggers the SWRCB Order 95-10 one-for-one requirement. A fifth reason involves a formal policy statement adopted by the MPWMD Board in February 1997. Current MPWMD policy specifically prohibits the future allocation of water previously set aside for drought reserve from the Paralta well (Exhibit 16-A). Even with the absence of the reasons enumerated above, a formal change to this policy would be needed before consideration of allocating additional Paralta water. In summary, additional production from the Seaside Basin should not be contemplated at this time due to the current physical status of the Basin, the legal uncertainties as well as the current limitations of the Cal-Am infrastructure. Cal-Am production in recent years has been closer to 3,500 AFA, and has enabled the community to stay within the estimated safe yield of 4,375 AFA for the Coastal Subareas. New production would thwart these efforts. Allocation of water from the Seaside Basin could be considered at some point in the future when: (a) legal issues are resolved; (b) more refined reliable yield limits are defined for individual aquifers and subareas within the Seaside Basin; (c) evidence of stabilized water levels in the Seaside Basin is available; and (d) Cal-Am system improvements and operational changes are made to facilitate increased production and distribution. ## Conservation Savings The District began a long-term conservation program in 1987 with a 15% reduction goal. To date, an estimated 2,040 AF have been permanently saved through District programs. The program fosters increased conservation awareness and several ordinances/programs that encourage and/or require water-saving habits and fixtures. Cal-Am production in water year 1987 was 18,117 AF as compared to an average of 14,500 AF in the past five years, a decrease of 20%. This reduction is significant in light of the fact that the number of Cal-Am customers rose from 33,708 connections in 1987 to 39,177 connections in 2002, a 16% increase. Notably, five of the last six years have been normal or above normal rainfall years. Conservation to date has allowed the community to stay below the SWRCB limit, and has allowed more people to use reduced resources (15,285 AFA maximum from Carmel River and Seaside Basin sources). It has been suggested to tap some of the conservation savings. Concerns include greater risk of exceeding set resource limits if more people “join the lifeboat.” Recent years have been normal or wet; the community has not experienced a string of dry/critically dry years since 1987-1992. This raises the question of how more rigorously people can conserve in a drought without creating hardship. Conservation is relatively volatile as compared to physical solutions due to changing weather and economic patterns, and human behavior. Again, conservation savings are not a new physical supply of water—all Cal-Am water stems from the Carmel River and Seaside Basins. For these reasons, conservation should not be used as a “source” of water. Other Potential Sources of Near-Term Supply The following sources might be available in the future. All would require environmental review under CEQA, as well as significant state (and possibly federal) permits. Aquifer Storage and Recovery (ASR) in Seaside Basin The MPWMD has been evaluating the feasibility of the ASR concept since 1996. ASR entails diverting and treating excess winter flows from the Carmel River Basin, and transporting the treated water by pipeline to the Seaside Basin, where the water is injected into specially-constructed ASR wells, for later recovery during dry periods. In May 1998, the District constructed a pilot injection well in the Paso Robles aquifer of the Seaside Basin. Based on promising results of injection testing in 1999 and 2000, the District constructed a larger, deeper injection test well, known as the Santa Margarita Test Injection Well (SMTIW) in April 2001 on the former Fort Ord. The Santa Margarita aquifer is more productive, and is therefore more conducive to a full-scale ASR project. Under a series of temporary water right permits from SWRCB, 596 AF were injected at the pilot well in 1998-2002, and 345 AF were injected at the full-scale site in 2001-2003, for a total of 941 AF injected at both wells to date. Notably, this water would have flowed to the ocean if the MPWMD program had not been in place. Instead, it is stored in the Seaside Basin, and is available for use. Much has been learned about the hydraulic response of these two target aquifers, as well as various operational and maintenance issues that would be attendant to a full-scale ASR project in the basin. A principal finding from this testing is that ASR wells completed in the Paso Robles aquifer, although less expensive to construct, would be limited to fairly low injection capacities of approximately 350 gallons per minute (gpm), whereas Santa Margarita aquifer ASR wells are capable of injection capacities of about 1,500 gpm, and extraction capacities of 3,000 gpm or more. Water Year (WY) 2002 was the first season during which a significant quantity of Carmel River Basin water was injected into the full-scale SMTIW (i.e., 175 AF). Accordingly, the District worked with Cal-Am to seek approval from the California Department of Health Services (CDHS) to recover the injected water for delivery back into the Cal-Am distribution system, as a means to evaluate recovery efficiency and chemical interactions during storage. Due to concerns about the fate of disinfection by-products in the recovered water, CDHS approval was not issued in 2002, but was issued upon completion of additional water quality testing for a limited period in 2003. A total of approximately 440 AF was recovered during this period, which is about 130% of the volume injected into the Santa Margarita aquifer since the SMTIW well was completed. This means that 345 AF of water (Carmel River source) were recovered and delivered to the community; this water would not have been available if the ASR program did not exist. Extensive water quality sampling was conducted during recovery. Results indicate that the recovered water was a blend of injected Carmel River system water and native groundwater, and that the recovered water retained some chemical imprints of the Carmel River system water even after 100% of the injected volume was removed. This suggests that injection is capable of “conditioning” the aquifer beyond the original volume injected, and reducing the occurrence of hydrogen sulfide in the native Seaside groundwater, which is an ancillary benefit of the ASR program. Engineering feasibility evaluations performed in association with the MPWMD desalination project EIR indicated that ASR is most promising at a smaller scale (700-1,300 AFA production), as a project that size can rely primarily on existing Cal-Am facilities. A larger project that would require extensive new extraction, treatment, transmission and injection facilities was not deemed to be cost-effective by the consultants. A full-scale project must obtain long-term water rights permits from the SWRCB as well as several permits from other agencies. The District has filed a water rights application with the SWRCB for a long-term ASR project. Importantly, an ASR project must still comply with the one-for-one aspect of Order 95-10, and thus could not be used for new construction and remodels. However, ASR is worthwhile to pursue because it can help stem the declining water levels in the Seaside Basin by “filling the groundwater trough” that exists due to current pumping practices. In-Lieu Recharge In 2003, the District asked SWRCB executive staff to consider amending Order 95-10 to mitigate adverse impacts to the Seaside Basin that are consequences of the Order. Specifically, the District requested that the SWRCB consider approval of “in-lieu recharge.” This concept entails additional use of the Carmel River by Cal-Am (i.e., divert more than 11,285 AFA) in wet years, when Carmel River flow is plentiful, so that pumping from the Seaside Basin can be reduced to allow the Seaside Basin to “rest” and recharge. A related Water Availability Analysis prepared by MPWMD for the SWRCB shows that up to 7,200 AFA is available in average years, and over 10,000 AFA is available in wet years, based on streamflow guidelines prepared by the National Marine Fisheries Service in June 2002. In-lieu recharge would be most effective in May and June of wet years, when the river would still be flowing at relatively high rates. Conceptually, in-lieu recharge could facilitate greater use of the Seaside Basin by Cal-Am in dry years to avoid impacts to the Carmel River. Such a scenario would allow greater operational flexibility to respond to changing weather cycles. The SWRCB staff rejected the District’s request for approval of near-term in-lieu recharge in a letter dated January 14, 2004. The rationale included: (1) Cal-Am should be making the request as the Order 95-10 is directed toward Cal-Am; (2) concern that other Seaside Basin pumpers may increase use, thereby obviating the benefits of reduced Cal-Am pumping; (3) there may not be significant additional water available from the Carmel River Basin; and (4) increasing Cal-Am’s diversion from the Carmel River is contrary to the intent of Order 95-10, and does not encourage solutions to replace use of Carmel River water. OVERALL SUMMARY AND CONCEPTS FOR CONSIDERATION: The MPWMD Board should review and discuss the following concepts: 1- Recognize Limits Have Been Imposed on Our Community Water supply planning since the 1980s has been “bottom-up”—that is, how can we best combine various water supply sources to determine the Allocation Program Cal-Am production limit. This way of thinking does not apply to today’s reality since SWRCB Order 95-10 was issued in 1995. We are now operating under a “top down” system. The SWRCB has limited Cal-Am’s Carmel River diversions to 11,285 AFA with only one exception — entitlement water for Pebble Beach up to 380 AFA. Current MPWMD Rules and Regulations set a Cal-Am production target of 4,000 AFA from the Seaside Basin, but cooperative Cal-Am/MPWMD efforts in recent years have focused on a 3,500 AFA planning target. With this in mind, the current “water pie” (Cal-Am production limit) is limited to 15,285 AFA (11,285 + 4,000 = 15,285) until some significant new physical source of water is developed that first offsets the unlawful Carmel River diversion described in SWRCB Order 95-10 (10,730 AF estimated). However, prudent (lower risk) planning suggests that the “water pie” should actually be no larger than 14,785 AFA Cal-Am production (11,285 + 3,500 = 14,785) under the existing production and management conditions, and the legal situation in the Seaside Basin. A larger amount could be considered when Seaside Basin concerns are resolved. 2- Recognize Misconceptions About Available Water Sources Some have mistakenly characterized that there are physical “pots of water” waiting to be used. This is not accurate. The only supply sources for the Cal-Am system are the Carmel River and Seaside Basins. “Releasing water” from reclamation or conservation savings does not provide a new physical source of supply; it is the same Cal-Am system. Also, if it were an actual new physical source of supply, then SWRCB Order 95-10 restrictions (one-for-one) would limit use. Other physical and regulatory limitations to the Cal-Am system constrain current production as compared to capacities in the past. 3- Prepare an EIR on the MPWMD Water Allocation Program Based on Existing Limits and Current Water Use Trends District Counsel has advised that releasing water for new construction and remodels must entail a new EIR on the Water Allocation Program. The EIR should address the changes that occurred in 1995 with Order 95-10 as well as other significant changes such as the Endangered Species Act (ESA) listing of steelhead and red-legged frogs in the Carmel River. If an EIR is to begin preparation in 2004, a proposed project and alternatives must be characterized in the near future. If a specific proposal cannot be crafted in the near-term, then MPWMD as lead agency could develop project alternative descriptions that at least bracket the option that may eventually be selected. The EIR should address the environmental effects associated with: (1) how much water is available to allocate; (2) who gets how much water; and (3) how should the current tabulation of 156 AF remaining allocation to the jurisdictions be handled? The first question reflects the risk of going over the 11,285 AFA Carmel River limit (see Exhibit 16-B for a summary of actual Cal-Am Carmel River diversions as compared to the SWRCB limit). The second question will determine cumulative growth impacts, which will be an important chapter in the EIR. The third question affects how much water would be available for “new” allocations in addition to (or possibly replacing) those that are presently “on the books” for each jurisdiction. Key questions for Board and/or committee discussion include: 1. How much water is used from the Carmel River and Seaside Basins now? 2. How does this compare to the SWRCB limit on Carmel River diversions and the Seaside Basin production target? 3. How much potential “wiggle room” is there to approve new construction and remodels, thereby allowing more people to use the same water resources under current constraints, and not go over the 11,285 AFA SWRCB limit? 4. What policy should be adopted regarding the trade-off between economic viability and the ability to implement General Plans versus the higher potential need for the community to: (1) further “tighten our belt” (actual rationing in a non-drought setting) more frequently or more stringently than under the current Ordinance No. 92 in order to stay under SWRCB limit and avoid fines; (2) go over the Seaside Basin Cal-Am target (or over the estimated safe yield of the Coastal Subareas) to avoid going over the Carmel Valley limit, keeping in mind that physical or legal constraints in an adjudication setting may limit Seaside Basin use; and (3) potentially being extensively fined by SWRCB if the Carmel River diversion limit is exceeded? 5. Should there be additional “jurisdictions” that receive a share, such as an MPWMD Community Reserve and/or the US Army or other military community? 6. Should the December 2003 estimate of 156 AF existing allocations be preserved or not? Should only a portion be preserved for pending projects that will come on line within the next 1-2 years? 7. How should logistical issues relating to available funds in the MPWMD budget and the process to retain a consultant be handled? A small amount of funding is included in the FY 2003-2004 to begin the EIR process on the Water Allocation Program. The Board must address funding questions for the FY 2004-2005 budget in order to complete the EIR. A possible option is to solicit joint funding and in-kind services from member jurisdictions to reduce District expenditures in FY 2004-2005. It is notable that whenever an EIR is prepared, current limits and allocations could change, as occurred as the result of the 1990 EIR. The existing remaining allocation amounts, as tabulated in MPWMD monthly reports, could be affected by the new production limits and distribution formulas that emanate from a new EIR. The December 30, 2003 estimated jurisdiction allocation total of 156 AFA from Paralta well and “pre-Paralta” sources are not entitlement water, and can be changed or removed through an EIR process. These quantities will remain available for use until a new EIR is certified and ordinances creating a new system are approved. The Water Allocation Program EIR will need to calculate a reasonable estimate of how much of the 156 AF is expected to be used before the EIR is certified, and incorporate that information into all environmental assessments. The use of all or part of the 156 AF currently “on the books” will affect the total amount of water available to allocate. A key future issue is how to ensure jurisdictions do not exceed their allocation limit. Discussion of the best means to achieve this goal includes the concept of the jurisdictions being responsible for staying within their limit. This raises implementation issues that would need to be addressed, such as monitoring water use, data tracking and management, enforcement, agency responsibilities, etc. Extensive discussion is assumed to occur in the future regarding these issues. SPECIFIC ALLOCATION CONCEPTS: The following allocation concepts are offered to foster discussion by the MPWMD Board: 1. Regardless of the “source,” any new allocation amount contemplated will result in a physical effect to the Carmel River Basin, and increase the risk of exceeding the 11,285 AFA limit set by the SWRCB. The higher the allocation, the greater the risk. 2. As a “higher risk maximum,” no more than 560 AFA total should be allocated. The 560 AFA represents the average Cal-Am production below the 11,285 AFA SWRCB limit from 1998 to the present (Exhibit 16-B) and makes the assumption that the overage in year 1997 was an anomaly. This may or may not be true, as five of the last six years were normal or above-normal water years. There are no recent data for community performance in a series of dry or critically dry years. 3. If it assumed that all of part of the current remaining jurisdiction allocation of 156 AF “on the books” will be used within the next year or two or should be preserved, then the maximum 560 AFA amount would be comprised of the 156 AF currently set aside for jurisdictions, plus 404 AFA from “new use” from the Cal-Am system. Exhibit 16-C provides a matrix that addresses this issue. 4. As an “intermediate risk maximum,” no more than 260 AFA should be allocated. This number is based on the 1997-2002 average Cal-Am use in the Carmel Basin (Exhibit 16-B), and includes the year 1997, when the community did exceed the SWRCB diversion limit. If the 156 AF “on the books” for jurisdictions is to be preserved, there would be 104 AF available to allocate for new uses. 5. As a “lower risk maximum,” no more than 100 AFA should be allocated. The 100 AF reflects the closest the community has come to the limit (106 AF), except for year 1997 (Exhibit 16-B). Only 100 of the existing 156 AF allocations could be preserved under this scenario, with no water to new uses. 6. The safest and most conservative course of action would be to limit new allocations to zero until current concerns, problems and disputes have been resolved. There is always the risk the community will go over the SWRCB limit each year, but having no new allocations would minimize such a risk. The discussion under “Pebble Beach Reclamation Project - MPWMD Share” suggested no more than 140 AFA should be considered. Because the 140 AFA would physically be Cal-Am potable supply emanating from the Carmel River, the 140 AFA is not additive to the “high, medium and low” scenarios described above. An increased allocation amount could potentially be considered when the Phase 2 Reclamation Project is completed and successfully operating (i.e., the goal of 800 AFA of Cal-Am production being replaced is achieved). District staff recommends that no allocation be made from the Seaside Basin or Conservation Savings at present. IMPACTS TO RESOURCES: MPWMD staff will need to (1) retain a consultant and carry out contract management duties; (2) provide extensive data, records, education, history, possible chapter text and other assistance to the consultant as he/she gears up; (3) coordinate with jurisdiction staff regarding needed information as well as status meetings; (4) review and edit documents; and (5) conduct other project management and coordination activities. The key divisions affected will be Water Demand and Planning & Engineering. The Water Resources Division will become involved for any tasks associated with computer modeling or aquatic or riparian habitat assessments. The cost of an EIR for a Water Allocation Program depends, in part, on the complexity of the proposed program and quantities of water involved. Costs of$200,000 to \$300,000 are not uncommon for projects of this nature, especially if there is extensive public comment or controversy.

EXHIBITS:

16-A:  February 1997 Board Policy Statement on use of Paralta Well drought reserve

16-B:  Carmel River diversions by Cal-Am in relation to SWRCB limits

16-C:  Conceptual allocation amounts with and without 156 AF preserved for jurisdictions

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FINAL 2/9/04