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It is difficult to quantify the risk to public health or the impacts to public <br />trust values. Further, EBMUD's proposed diversion may have very small impact <br />on either public health or public trust values. In the absence of conclusive <br />data, however, we believe that it is more reasonable to err in the direction <br />that will afford maximum protection to the public health. <br /> <br />The reasonableness of EBMUD's proposed diversion can also be evaluated by <br />comparing the alternative sources of water available to EBMUI3. As described <br />above, none of the alternatives ts clearly superior to EBIIUD's proposed <br />diversion of water from the American River. Based on this evaluation, we <br />conclude that EBMUD's proposed diversion of water from the American River via <br />the Folsom-South Canal is not unreasonable. <br /> <br />Analysis The proposed physical solution provides a practical approach t~ <br />maximizing beneficial uses of water and, at the sa~e time, recognizes the <br />existing development within the watershed and the manner in which the Fols~ <br />reservoir is operated by the Bureau. The proposal is a compromise betwe_~n ?.-= <br />EBMUD and the County proposals, i.e., it is less restrictive than the County's <br />but more restrictive than EBMUD's proposal. <br /> <br />Based on hydrology studies conducted by the Board, sufficient water would he <br />available to meet EBMUD's demand in most years. The maximum diversion of <br /> <br />1SO,ODD AFA by EBMUD would reduce the flow during the critical sunner period in <br /> <br />5 Of the 57 years of record. Our proposed physical solution would prohibit <br /> <br />EBMUD from diverting in 3 of those 5 critical periods. Thus, under the _ <br />proposed physical solution, EBMUD would cause a reduction in the level of flo~ <br />in the lower American River in 2 of the 57 years of record, or about once each <br /> <br />30 years. <br /> <br /> 23 <br /> <br /> <br />