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During the same hearings, Mr. Floyd E. Dominy, Commissioner, Department of the Interior, Bureau of Reclamation, stated that, "Our judgment at the moment, collective judgment of the Geological Survey and the water pollution people and the Bureau of Reclamation in the Department, would be that with full Upper Basin development the water quality at Imperial Dam would gradually worsen to probably something like 1,400 parts per million of dissolved minerals." (Transcript page 854).

Assuming that the Colorado River water delivered to Imperial Irrigation District reaches the salinity index of 1,200 ppm by the year 2000, the leaching factor requirement (based on the Blaney-Criddle formula by direct proportion) will increase from 22% to 29%. We realize that soil susceptibility is a factor in applying this quantity of leaching water. When one considers that Imperial Irrigation District diverts 2.9 million acre-feet of water, now averaging approximately 900 ppm, it is very apparent that a further deterioration in quality of the water coming into our system will mean that a considerably greater quantity of water will be required to do the same job we are doing now, based on this premise. In view of the limitations imposed as to quantity-namely, those prescribed by the contractual agreements referenced earlier-an increased leaching requirement on the part of Imperial Irrigation District will, of course, operate to the disadvantage of the contractors without present perfected rights or other rights of appropriation.

COACHELLA CANAL AND EAST MESA LANDS

Concerning the matter of lining the Coachella Branch of the All American Canal, the Imperial Irrigation District is willing, under certain conditions, to relinquish its capacity interests in that canal to facilitate its lining by the United States. There are approximately 4,200 acres of East Mesa land, which have been included and have a certificate of water availability, that are contiguous to the Coachella Canal and subject to irrigation therefrom without crossing public lands. Approximately 10% of these 4,200 acres were shown to be in crop during 1973.

Realizing that the 4,200 acres of land contiguous to the Coachella Canal could be served by approximately 100 cfs of capacity, the fact remains that the District contracted for 1,000 cfs capacity in the main, as well as in the Coachella Branch of the All American Canal to serve the East Mesa lands, approximately 220,643 gross acres (see Exhibit 27F0189). The District's 1,000 cfs capacity, if constructed, would add approximately 13 million dollars in addition to the projected 20 million dollar cost for the Coachella Valley County Water District's 1,500 cfs capacity.

A major part of the East Mesa Unit is public land, and the District's contract with the United States, namely, Contract Ammendatory of and Supplemental to All American Canal Contract of December 1, 1932, dated March 4, 1952, provides in Article 23, "Assessment of Public Land", the following, and I quote: "Within a reasonable time, to be determined by the Secretary, from the date water is available for and can be delivered to any public lands within the boundaries of the District, such lands shall be opened to entry."

Taking this provision of the contract literally, the District, as explained above, contracted for capacity in the main, as well as in the Coachella Branch of the All American Canal to serve said lands. However, since California, as a result of the decision in Arizona v. California, is obligated to reduce diversions less returns to 4.4 million acre-feet per year in the future, any lands opened for entry on the East Mesa would have to be served to the detriment of other users. We do not intend this.

In the matter of Hugh S. Ritter, Thomas M. Bunn (A–30415), decided February 24, 1965, the Under Secretary of the Interior ruled that, "it would be contrary to the public interest at this time to increase the pressure on the inadequate water supply available for use in California from the Colorado River by classifying *** public lands as available for disposition under the desert land law." The lands referred to are in Imperial and Riverside Counties, California. The above is from 43 CFR 2234.3-1, and is quoted further as follows: "For the reasons stated in the Ritter-Bunn decision, supra, it is contrary to the public interest to permit the use of federally owned lands within Imperial and Riverside Counties for the construction of canals and ditches in order to effect agricultural reclamation with water from the Colorado River of desert lands in those counties. Therefore, no applications for rights-of-way for this purpose under the provisions of the Act of March 3, 1891, as amended, will be allowed or permitted on federally owned lands within Imperial and Riverside Counties, Calif., unless the applicant shows that the water

to be carried is from a source other than the Colorado River." The Secretary continues to hold that East Mesa lands non-contiguous to the main All American Canal and to the Coachella Branch are not subject to irrigation because of the water inventory, and the Government will not grant rights-of-way across public lands for this purpose, including access across the canal bank itself.

DISTRICT OPPOSED TO PROVIDING CAPACITY IN COACHELLA BRANCH CANAL FOR EAST MESA LANDS

Furthermore, even though the District had been authorized to expand the acreage entitled to water pursuant to the All American Canal contract, providing water is available, we would, in good conscience, have to decide not to do so insofar as these particular lands are concerned.

To reinforce this position, reference is made to two contracts with the Federal Government. The first, No. 14-06-300-615, dated April 30, 1957, covering the lease of land for agricultural purposes known as the Drop No. 3 Experimental Farm, which was terminated as of October 30, 1973 because of its failure to become economically self-supporting due to limitation of crops, excessive water duty, and inadequate drainage (see Exhibit 27F0189 for location). The second, No. 14-06300-613, dated May 1, 1947, amended April 30, 1957, covering the lease of land for agricultural purposes known as the Drop No. 2 Experimental Farm, following initial development by the District was sublet to Brock Ranches for a long-term study to determine the feasibility of commercially producing various citrus crops on the East Mesa (see Exhibit 27F0189 for location). Water duty on the farm over the past ten years of operation has averaged 22.4 acre-feet per acre, with no indication that this rate of application will improve to any great extent.

Therefore, Imperial Irrigation District believes that the land included in the East Mesa Unit, except the experimental farm referenced herein, should not be opened to entry under any circumstances and, further, that the District should be relieved of responsibility for serving irrigated, as well as unirrigated, privatelyowned lands on the East Mesa adjacent to the Coachella Canal by means appropriate to the United States including purchase, exchange, eminent domain, or condemnation of said private lands or interest therein at no cost to the District.

LEACHING REQUIREMENT IMPERIAL UNIT

Reference is, again, made to the presentation of Imperial Irrigation District in hearings before the Sub-committee on Irrigation and Reclamation of the Committee on Interior and Insular Affairs, House of Representatives, during consideration of H.R. 3300 and S.B. 1004 on February 2, 1968, and to certain exhibits attached thereto. Exhibit T-1033, titled, "Water for Consumptive Use and Leaching Requirement and Theoretical Farm Efficiency, 1959-66", and resubmitted here under the same designation, shows an eight-year average consumptive use per acre irrigated of 4.26 acre-feet and a leaching requirement factor of 20%. Exhibit T-1063, attached hereto, updates the previous exhibit and shows a tenyear average consumptive use of 4.24 acre-feet per acre irrigated and a leaching factor of 21%. It will be noted that for the year 1972, the consumptive use factor was down slightly, but the leaching factor rose to 22%, which correlates with the figure previously mentioned.

It follows, however, that if the Colorado River water quality improvement feature of the Bill is implemented, resulting in improved quality in flows arriving at Imperial Dam, then, obviously, Imperial's leaching requirement would be reduced accordingly, and water saved would be available to assist in the satisfaction of the demands of the Coachella Valley County Water District and The Metropolitan Water District of Southern California.

CONCLUSION

The Imperial Irrigation District, occupying a position at the tail end of the Colorado River system, isperhaps, more interested in alleviation of salinity than those who are more furtunate and are located in the upper reaches.

The District has faced up to its problems of silt and salt in the past, and expects to continue to do so in the future. For example, it will be necessary, as shown in the annexed tabulation, to expend approximatel $167 million dollars to complete the District and landowners' concrete lining and tile drain programs. The total overall capital outlay, on completion, will exceed $264 million dollars.

The Imperial Irrigation District has made and is making its contribution, and we feel that it is appropriate, as well as timely, for the United States to do its part to reduce salinity of the waters reaching us.

Imperial Irrigation District does not desire a reduction of its rights or obligations with respect to the main All-American Canal, and prefers that the obligations with respect to the main All-American Canal, and prefers that the full capacity of the main canal be maintained.

If there are to be changes in any water delivery contracts, they will be amendments or supplements negotiated between the Secretary and the particular water user, such as Imperial Irrigation District or Coachella Valley County Water District, without effect on contractual rights of others.

We annex amendments to both bills to carry out the foregoing recommendations. Imperial Irrigation District takes this occasion to state its appreciation for the efforts of the Committee of Fourteen, and its support, in principle, of the Committee's recommendations.

The Imperial Irrigation District believes that the Government should move forward with its obligation to fund this legislation to accomplish the objective as a national obligation. We strongly recommend enactment of H.R. 12165, because it comes to grips with the salinity problem on a basin-wide basis.

EXHIBIT A.-AMENDMENTS PROPOSED BY IMPERIAL IRRIGATION DISTRICT TO H.R. 12165, 93d CONG.

P. 9, line 1: Strike all commencing with "authorized" and substitute: "to return such lands to the public domain, but withdrawn from entry. The United States shall not acquire any water right by such acquisition of lands." P. 9, line 9: Strike "All American and". Change "Canals" to "Canal".

AMENDMENTS PROPOSED BY IMPERIAL IRRIGATION DISTRICT TO H.R. 12834,

93D CONG.

Page 4, line 5: Strike “All-American and”, Change "Canals” to “Canal”. Page 4, line 17: Strike through line 22, and substitute: "return such lands to the public domain, but withdrawn from entry. The United States shall not acquire any water right by such acquisition of lands."

APPENDIX

IMPERIAL IRRIGATION DISTRICT: LINING AND TILE COSTS

With respect to: (1) the costs regarding tile installed; (2) cost of concrete lining District laterals from 1954-1972, inclusive; (3) estimated costs of private farm ditches installed by landowners at their expense from 1949-72, inclusive; (4) tile required, as programmed, based on past experience for future installation, cost of additional tile required if existing tile spacing is reduced to 100-foot intervals; (5) projected costs of concrete lining to be considered in future years; and (6) the

estimated costs of concrete lining the District's main canals which, presently are unlined, the following information is submitted:

Period

1. Value of tile installed since 1929 within Imperial Irrigation District
boundary:

1929-30-17.53 miles at $528 per mile.
1931-40-382.08 miles at $950 per mile..
1941-50-2,017.14 miles at $1,690 per mile.
1951-60-5,754.67 miles at $2,112 per mile.
1961-70-7,723.99 miles at $2,482 per mile.
1971-919.34 miles at $2,798 per mile.
1972-1,019.40 miles at $2,798 per mile.

2. Cost of concrete lining district laterals from 1954-72, inclusive (524.15
miles)..

3. Costs of private farm ditches installed by landowners at their expense 1949-72 inclusive (1,848.30 miles)..

4. Presuming a 100-foot spacing concept is accepted, the application of
the appropriate formula develops the following:

Tiling requirements to complete tile systems in cultivated area
IID 17,834 miles tile installed (1929-72)-94,000,000 feet or
377,000 acres; Average spacing needed plus minus 100 feet;
100-foot space per 160 acres equals 65,000 feet to tile.

65,000 over 160 equals 400 feet per acre to tile complete to 100 feet
Existing tile 94,000,000 feet over 377,000 acres equals 250 per feet
per acre existing

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400 feet per acre-250 feet per acre equals 150 feet per acre needed
for split out; 150 feet times 377,000 equals 57,000,000 feet needed
for split-out; 57,000,000 feet at $0.053 per foot...
New tile-120,000 acres untiled (59,000 acres-no tile; 61,000
acres partial tile); 120,000 acres times 400 feet per acre equals
48,000,000 feet new tile; 48,000,000 feet at $0.053 per foot..

30,200,000

25,400,000

Total estimated cost of tile for 105,000,000 feet..

Note. For the year 1972, total tile footage under new tile design numbers was 918,000 feet. Total footage for year-5,160,000 feet. Total jobs for the year 1972 were 360, of which 36 were new grids. Therefore, 10 percent of all tile jobs were new grids representing 16.8 percent of all footage installed or 83.2 percent of all tile installed was split-outs.

5. Projected cost for concrete lining balance of district lateral canals in future years..

6. Estimated projected 1983 cost of concrete lining district main canals

are as follows:

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55,600,000

28, 013, 300

46,500,000 23, 400, 000 39, 000, 000 3, 000, 000 2, 000, 000

141,913, 300

264, 279, 100

The information submitted covering the costs of tile lines and concrete lined ditches installed has been developed from available records.

The estimated costs of additional tile lines, as well as new lines to be installed to split out existing lines; and the concrete lining of lateral as well as main canals, has been estimated, using cost information developed from our records to which there has been added what we believe to be an appropriate increase to accomplish the work proposed.

IMPERIAL IRRIGATION DISTRICT

SALINITY OF IRRIGATION WATER RECEIVED BY DISTRICT AND LEACHING REQUIREMENT 1964-66

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a Total discharge all-American canal below drop 1.

b Based on weekly salinity samples.

• Based on conversion factor of 0.7 for ppm to conductivity (micromhos/cm. to nearest 10).

d Based on average salt tolerance for 50 percent yield reduction and historic conductance of water delivered to district. Refer USDA Handbook No. 60 and Bulletin 283. Includes allowance for minimum nonuniformity of application.

e

Weighted average.

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