HomeMy WebLinkAbout25I - AGMT - WATER DELIVERIESREQUEST FOR
COUNCIL ACTION
CITY COUNCIL MEETING DATE:
AUGUST 15, 2017
TITLE:
APPROVE AGREEMENT WITH
METROPOLITAN WATER DISTRICT AND
THE MUNICIPAL WATER DISTRICT OF
ORANGE COUNTY FOR IN -LIEU
TREATED WATER DELIVERIES
(NON GENERAL FUND)
{STRA GIC PLAN NO. 5, 2
CI A AGER
RECOMMENDED ACTION
CLERK OF COUNCIL USE ONLY:
APPROVED
❑ As Recommended
❑ As Amended
❑ Ordinance on 15t Reading
❑ Ordinance on 2ntl Reading
❑ Implementing Resolution
❑ Set Public Hearing For
CONTINUED TO
FILE NUMBER
Authorize the City Manager and Clerk of the Council to execute an agreement with the
Metropolitan Water District and the Municipal Water District of Orange County for in -lieu treated
water deliveries, subject to nonsubstantive changes approved by the City Manager and City
Attorney.
DISCUSSION
The Metropolitan Water District (MWD) is a wholesale water provider to its 26 member agencies;
the City of Santa Ana and the Municipal Water District of Orange County (MWDOC) are member
agencies of MWD. MWD provides imported surface water to the Southern California region from
both the Sacramento Bay Delta to the north, and the Colorado River to the east. A significant
amount (approximately 25 percent) of water supplied by the City of Santa Ana to its residents and
businesses is purchased from MWD. The balance of water supplied by the City is pumped
groundwater from the Orange County Basin, and the city footprint lies over the Basin.
The heavy rains and snowfall experienced across the State during the winter season of 2016-2017
has resulted in an abundance of surface water runoff into the Sacramento Bay Delta. This surface
water must be stored, consumed, or allowed to flow into the ocean. As a result, MWD has filled its
reservoirs and must find additional storage space and use for the surface water, or risk losing this
precious resource to the ocean.
One strategy available to MWD is to ask groundwater producers, such as Santa Ana, to increase
the amount of MWD surface water they use, and decrease groundwater pumping. This "in -lieu
pumping" (water banking) strategy will allow Santa Ana to save its basin groundwater. In future
years, when surface water supply conditions are less abundant, the City will do the opposite:
pump more groundwater out of the basin and save surface water.
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Agreement with MWD and MWDOC for In -Lieu Treated Water Deliveries
August 15, 2017
Page 2
The water banking process has to be carefully monitored and accounted for to ensure that the
participating agencies exchange appropriate amounts of surface water and groundwater to
achieve an overall net $0 cost to the water enterprise. The proposed in -lieu agreement
implements a number of administrative procedures to establish proper accounting. In the
assigned roles, MWD supplies water to the City, MWDOC verifies volume of water deliveries and
carries the balance sheet for all Orange County participants, and the City pays related invoices to
MWD.
STRATEGIC PLAN ALIGNMENT
Approval of this item supports the City's efforts to meet Strategic Plan Goal #5 — Community
Health, Livability, Engagement & Sustainability, Objective #2 (expand opportunities for
conservation and environmental sustainability).
FISCAL IMPACT
There is no environmental impact associated with this action.
FISCAL IMPACT
There is no fiscal impact associated with this action. The administrative procedures established
by this agreement ensure a net $0 cost to the water enterprise.
Exedutive Director
Public Works Agency
FM/NS/RR
Exhibit: 1. Agreement
251-2
Agreement
Between Metropolitan Water District of Southern California,
City of Santa Ana, and MWDOC
for Fiscal Year 2017/2018 In -Lieu Treated Deliveries
This Agreement is made as of 2017, by and among the METROPOLITAN
WATER DISTRICT OF SOUTHERN CALIFORNIA ("Metropolitan"), a public agency of
the State of California, the Municipal Water District of Orange County ("MWDOC"), a
public agency of the State of California, and the City of Santa Ana ("City"), a charter city of
the State of California (collectively, the "Parties").
Section 1. Purpose of Agreement.
a. Metropolitan is a wholesale provider to its 26 member agencies, created under The
Metropolitan Water District Act ("MWD Act"). Wat, Code appen., §§ 109-25, 109-
130.
b. MWDOC is a member public agency of Metropolitan and a wholesale water provider
with a service area overlying the Orange County Basin, a groundwater basin located
in Orange County, MWDOC was created under Municipal Water District Act of
1911.
c. City is a member public agency of Metropolitan and a retail water provider with a
service area overlying the Orange County Basin, a groundwater basin located in
Orange County.
d. Metropolitan and MWDOC have entered into an agreement ("MWDOC-Metropolitan
Cyclic Storage Agreement") which provides for the delivery of water by Metropolitan
to MWDOC in advance of demand for the water by MWDOC through a cyclic
storage account ("MWDOC-Metropolitan Cyclic Storage Account").
e, Through this Agreement, the Parties intend to provide for a means of delivering water
from Metropolitan through City into the MWDOC-Metropolitan Cyclic Storage
Account.
Section 2. Designated In -Lieu Treated 'Deliveries.
City represents and Metropolitan has confirmed that its ability to accept untreated
Metropolitan water, originating or blended with State Water Project water, is impacted due to the
detection of unconfirmed quagga mussels. Accordingly, City agrees to take up to 9,500 acre-feet
of treated water from Metropolitan for delivery into the MWDOC-Metropolitan Cyclic Storage
Account through in -lieu means ("In -Lieu Treated Deliveries"), The actual amount of In -Lieu
Treated Deliveries may be higher or lower based on operational conditions and the In -Lieu
Treated Deliveries Certification Procedures referenced in Section 8. In -Lieu Treated Deliveries
will be made upon Metropolitan's written request and the City's written acceptance, in the City's
sole discretion, of additional treated water deliveries.
Agreement
Between Metropolitan Water District of Southern California,
City of Santa Ana, and MWDOC
for Fiscal Year 2017/2018 In -Lieu Treated Deliveries
City represents and warrants that In -Lieu Treated Deliveries are in addition to its
projected full service deliveries from Metropolitan (treated or untreated), which would normally
occur without this Agreement.
MWDOC represents and warrants that, in accordance with the MWDOC-Metropolitan
Cyclic Storage Agreement, an amount equivalent to the In -Lieu Treated Deliveries will be,
credited to Metropolitan as stored water in the Orange County Basin, pursuant to the City's
intentional reduction in groundwater production certified and reconciled according to Section 8,
until such time as the water is purchased by MWDOC pursuant to the terms of the MWDOC-
Metropolitan Cyclic Storage Agreement and Section 8 of this Agreement.
Section 3. Tenn.
This Agreement shall be effective until the last acre-foot of water delivered under this
Agreement is purchased out of the MWDOC-Metropolitan Cyclic Storage Account and is
applicable only to In -Lieu Treated Deliveries made to City Linder this Agreement from July 12,
2017 through June 30, 2018, as certified and reconciled according to Section 8.
Section 4. Treatment Surcharge Payment,
City agrees to pay Metropolitan the Treatment Surcharge effective at the time of the In -
Lieu Treated Deliveries, which for calendar year 2017 is $313 per acre-foot and in calendar year
2018 will be $320 per acre-foot.
Section 5. Storage Price Tenn.
In exchange for the City's acceptance and storage of In -Lieu Treated Deliveries for
Cyclic Storage in fiscal year 2017/18, instead of direct untreated water deliveries, Metropolitan
agrees to pay City up to $225/acre-foot, as determined by Metropolitan pursuant to Section 6.
Section 6. Determination of Storage Price Term.
Metropolitan has, in its sole discretion, determined the Storage Price Term is $212 per
acre-foot in 2017 ($313 - $101) and $219/acre-foot in 2018 ($320 - $101). Metropolitan has
made such deternination based on an estimate of costs incurred by City as a result of taking in -
lieu delivery of additional treated water at Metropolitan's request that City would not otherwise
have taken, minus the costs that City would have incurred if it produced an equivalent amount of
water from the Orange County Basin. City has submitted its avoided cost estimates to
Metropolitan, which Metropolitan reviewed in addition to historical production cost estimates
available to Metropolitan,
City may, at any time prior to reconciliation and certification described in Section 8,
request a redetermination of the Storage Price Tenn, by submitting documentation that its
groundwater production costs have changed. Metropolitan shall, in its sole discretion, change
251-4
Agreement
Between Metropolitan Water District of Southern California,
City of Santa Ana, and MWDOC
for Fiscal Year 2017/20181n -Lieu Treated Deliveries
the Storage Price Tenn upon review of any such additional documentation and confirmation of
changes in costs.
Section 7. Billing Procedures
Metropolitan will bill City the Treatment Surcharge in effect at the time City certifies the
In -Lieu Treated Deliveries, in the same manner as Metropolitan bills City for all other water
sales, Metropolitan will pay City the Storage Price Term for In -Lieu Treated Deliveries in fiscal
year 2017/18 by applying a credit to City's meter invoiced amounts, which credit is subject to
the certification and reconciliation process described in Section 8.
Section 8. Certification of In -Lieu Treated Deliveries.
City shall submit monthly certifications of In -Lieu Treated Deliveries pursuant to this
Agreement consistent with Metropolitan's Administrative Code, sections 4506 to 4507. Such
certifications will be made pursuant to the In -Lieu Treated Deliveries Certification Procedures,
attached hereto and incorporated herein as Attachment 1. On a monthly basis Metropolitan will
review these certifications for conformance with the submitted operating plans submitted
pursuant to the In -Lieu Treated Deliveries Certification Procedures. After the end of fiscal year
2017/18, Metropolitan will reconcile the deliveries made pursuant to this Agreement during the
fiscal year, in order to ensure in -lieu deliveries were made in addition to normal full-service
deliveries and as a result of actions to reduce groundwater pumping.
Metropolitan will void any credits given for water deliveries that Metropolitan is unable
to reconcile as qualifying In -Lieu Treated Deliveries under this Agreement, which will result in
an equivalent charge to City's bill plus the applicable untreated full service rates and charges.
The total amount of all voided credits shall be billed in the next month following the end -of -year
reconciliation.
Section 9. Purchase of Water Out of Cyclic Account.
MWDOC agrees to purchase the In -Lieu Treated Deliveries made pursuant to this
Agreement out of the MWDOC-Metropolitan Cyclic Storage Account within five years of the
effective date of this Agreement. Billing and payment procedures shall be the same as other
purchases frorn the MWDOC-Metropolitan Cyclic Storage Account, as provided in the
MWDOC-Metropolitan Cyclic Storage Agreement.
Approved as to form: MWDOC
By: By:
General Counsel
251-5
Robert J. Hunter
General Manager
Agreement
Between Metropolitan Water District of Southern California,
City of Santa Ana, and MWDOC
for Fiscal Year 2017/2018 In -Lieu Treated Deliveries
Approved as to form:
Sonia R. Carvalho, City Attorney
By: 1_ llV lite
ll1 M. Funic
Assistant City Attorney
Attest:
in
The City of Santa Arra
Cynthia Kurtz
Interim City Manager
Recommended for Approval
By _ By:
Maria D. Huizar Fred Mousavipour
Clerk of the Council Executive Director, Public Works Agency
Approved as to form:
Marcia L. Scully
General Counsel
By:
General Counsel
No
251-6
The Metropolitan Water District
of Southern California
Jeffrey Kightlinger
General Manager
Attachment I
In-hieu 'Treated Deliveries Certification Procedures
For Cyclic Storage Agreement
Between Metropolitan Water District of Southern California
and the City of Santa Ana
1. Introduction
The purpose of this Attachment '1 is to assist the City of Santa Ana (Santa Ana) in its
certification of In -Lieu Treated Deliveries for its participation in the Agreement Between
Metropolitan Water District of Southern California (Metropolitan), The City of Santa Ana (Santa
Ana), and Municipal Water District of Orange County (MWDOC) for Fiscal Year 2017/18 In -
Lieu Treated Deliveries (Agreement). Pursuant to the Agreement, Santa Ana is eligible to
receive a credit in accordance with sections 4 and 5 of the Agreement (Storage Credit). To
qualify for the Storage Credit, Santa Ana must meet the requirements contained in these Ia-Lieu
Treated Deliveries Certification Procedures and in Metropolitan's Administrative Code Section
4507.
2, Administration
Aringal 02eratigg Plan
For Santa Ana to participate in this Agreement, they shall submit an Operating Plan to
Metropolitan's Water System Operations Group (WSO) for review prior to the beginning of the
operating period. WSO staff will review the operating plan and work with agency staff to
resolve issues and questions related to the operating plan. Operating plans for In-Lieu.Treated
Deliveries shall follow the form as outlined on the Excel worksheet provided by Metropolitan's
WSO staff.
Certification of In -Lieu Treated Deliveries
In order to obtain the Storage Credit, Santa Ana shall certify the amount of In -Lieu Deliveries
purchased from Metropolitan on the forms provided by Metropolitan. Metropolitan WSO staff
will perform a cursory review of dte certifications for mathematical accuracy upon their receipt.
Such a review does not preclude Metropolitan from correcting errors discovered as a result of
Metropolitan's annual reconciliation of the hi -Lieu Treated Deliveries under this Agreement.
Annual Reconciliation
Metropolitan WSO staff will complete an Annual Reconciliation of Santa Ana's in -Lieu Treated
Deliveries certifications within six months following receipt of final documentation from the
agency staff. During this period Metropolitan staff will work with Santa Ana staff to reconcile
any differences. If differences cannot be resolved, the Resolution of Differences section below
shall apply.
Santa Ana shall submit final documentation within six months after the end of the Fiscal Year
operating period. If final documentation is not submitted, Metropolitan will assume that the
water had been used for Full Service purposes, Santa Ana shall be obligated to pay the amount
AND CUP GERTIRCATION DOCUMENTATION.000
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of the credit that had been applied to the In -Lieu Treated deliveries and all other rates and
charges associated with Full Service Treated deliveries.
Listed below is the documentation that Santa Ana should maintain to support the Annual
Reconciliation. Metropolitan reserves the right to review original documentation.
• Original monthly groundwater production records for the previous three years.
• Original monthly production records from other local sources Monthly
Metropolitan deliveries,
• Monthly demands, excluding recycled water.
• Annual local water rights, preferably groundwater basin manager report.
• If a sub -agency, monthly water bill from member agency.
Resolution of Differences
If an impasse exists on the interpretation of the Agreement between the Santa Ana and
Metropolitan staff, Metropolitan's Water System Operations' Group Manager has the
responsibility to consult with Santa Ana and make a final ruling subject to the General
Manager/Chief Executive Officer's oversight. If the ruling on the issue is unsatisfactory to the
agency, it can be appealed to the Water Planning and Stewardship Committee of Metropolitan's
Board of Directors. The Water Planning and Stewardship Cormnittee shall consider such appeals
and make recommendations to the Board. The Board shall act upon such recommendations and
its decision shall be final.
3. Documentation for Planning, Tracking, Measuring and Certifying In -
Lieu Treated Deliveries under the Cyclic Storage Agreement
This Section 3. "Documentation for Planning, Tracking, Measuring and Certifying In -Lieu
Deliveries under the Cyclic Storage Agreement augments the Rate Handbook and, where
applicable, govern deliveries made under this Agreement. All forms are formatted as Excel
worksheets.
Worksheet 1, Operating Plan, consists of three sections. Section A, Historic Groundwater
Production; Section B, Planned Annual Operating Plan; and Section C, Actual -to -Date and
Planned Operations, Worksheet 2, Monthly Certification, is used to certify monthly In -Lieu
Treated Deliveries, Agencies should use the Monthly Certificationn worksheet to certify In -Lieu
Treated Deliveries made through a connection having more than one designated use.
Itis Santa Ana's responsibility to submit Sections A and B of the Operating Plan prior to the
beginning of the upcoming operating period, and to update Section C of the Operating Plan, as
needed, to reflect actual -to -date operations and any changes in planned operations, In order to
receive the credit on In -Lieu Treated deliveries under the Cyclic Storage Agreement, Santa Ana
must also submit a Monthly Certification to Metropolitan for each month that such deliveries
occurred. All certified water also would be subject to Certification and Billing Procedures
outlined in the Rate Handbook and subject to Administrative Code, Section 4507.
2
PORMSIREPLENISHMENT AND CUP CERTIFICA'110N OOCUMENTATION.00C
251-8
Lines on the forms requiring data input are highlighted in green, All other lines are calculated,
A line -by-line explanation of the forms follows with the symbol, "tV"designating a user input,
and the "R" symbol designating a calculated value:
Worksheet 1— Operating Pian
Section A - Historic Groundwater Production; Section A calculates an Adjusted Baseline that
is the basis against which monthly In -lieu Cyclic Storage deliveries will be measured. The
Adjusted Baseline should reflect the monthly pumping pattern Santa Ana would follow if it were
not planning to certify in -lieu deliveries from Metropolitan. The Adjusted Baseline is based on
historic groundwater production patterns; however, Santa Ana may adjust these patterns to
reflect anticipated system or operational changes during the corning operating year,
Lines Al, A2, & A3 - FY Groundwater Production: Santa Ana inputs previous three
years monthly groundwater production data beginning one-year prior to the end of the
last full operating period, For example, for an agency preparing its FY 2017-18
operating plan, the three years prior would include FY's 2014-15, 2013-14, and 2012-13.
Monthly groundwater production data includes actual pumped groundwater and imported.
in -lieu deliveries.
Line A4 - 3 -Year Historical Baseline: Spreadsheet calculates Santa Ana's average
monthly groundwater production from the past three years.
ria Line A5 - Adjustments to Baseline: Santa Ana inputs anticipated increases and/or
decreases in total monthly production due to factors such as new production wells
coming online, wells taken out of service, and/or other justifiable alterations in
production patterns.
Q Lire A6 -Adjusted Baseline: Spreadsheet calculates Santa Ana's Adjusted Baseline for
the coming operating year, i.e,, 3 -'Year Plistorical Baseline with Adjustments to Baseline
(positive or negative).
As indicated above, Lines A1, A2, A3, and A5 are user inputs to be provided by Santa Ana
prior to the beginning of the operating year for review by Metropolitan. This review may
require Santa Ana provide Metropolitan with records documenting historic well production
and rationale for Adjustments of Baseline.
Section B — Planned Annual Operating Plan: Section B is Santa Ana's projection of monthly
imported water deliveries, groundwater production, and other local supplies that will be used to
meet its retail demand. The Section functions as a planing tool for Santa Ana and Metropolitan.
It also calculates projected In -Lieu Treated Deliveries eligible for certification as Cyclic Storage
based on projected groundwater production. Although only an initial estimate, once completed,
Section B should remain static throughout the operating year and utilized as the baseline with
which to evaluate the year's actual progress.
,R Line B1 - Adjusted Baseline: This line carries forward Santa Ana's Adjusted Baseline
calculated in Line A6,
FORM$IRF.PLENISHMENT AND CUP CERTIFICATION OOCUMENTATION.000
251-9
Line B2 - Monthly Production Capability: Santa Ana projects the well capability
available for each month of the operating year. Available capability refers to the
operational status of facilities in place to extract groundwater for retail water use. For
example, the total capacity of Santa Ana's well field might be 50 cis, but four wells are
out service due to factors such as mechanical problems or diminished water quality. As a
result, only 38 cfs of the well field's 50 cfs capacity is actually available for production,
and 38 cfs would be considered Santa Ana's Monthly Production Capability.
9 Line B3 - Baseline: Spreadsheet calculates monthly Actual Baseline, i.e., the lesser of
the Adjusted Baseline or Monthly Production Capability. In -lieu water certified by
Santa Ana may not exceed its production capability for that month.
01 Line B4 - Planned Groundwater Production: Santa Ana inputs amount of
groundwater it plans to produce each month to meet retail demand.
n Line B5 — All Other Local Sources: Santa Ana inputs quantities of water it expects to
produce from all other local sources other than the groundwater basin to meet retail
demand. These sources include recycled, recovered groundwater, local runoff, imported
transfers, etc.
F Line B6 - Planned Import: Santa Ana inputs amount of water it expects to purchase
from Metropolitan to meet retail demand.
Q Line B7 — Total Retail Demand: Spreadsheet calculates Santa Ana's entire retail
demand, i.e., Planted Groundwater Production, plus All Other Local Sources, plus
Planned Import.
Q Line B8 — Estimated Monthly In -lieu Credit (Underproduction): Spreadsheet
calculates planned monthly groundwater underproduction, i.e., Baseline less Planned
Groundwater Production, If positive, indicates water being stored. If negative, indicates
water being taken out of storage (overproduction).
Section C — Actual -to -Date and Planned Operations: Initially completed with the identical
information as Section B — Planned Annual Operating Plan, Section C calculates actual In -Lieu
Treated Deliveries, updates projections shown in Section B with actual operational data, and is
used to revise projected operations, as needed, based on actual operations to date, Monthly In -
lieu Treated Delivery credit is applied to the volume difference between the Santa Ana's
Baseline and actual Groundwater Production.
Santa Ana is arpected to update this foran whenever Ira -Lieu Treated Deliveries are certifier,
Updates should include actual deliveries of groundwater, other local supplies and imported
deliveries that have occurred during the operating period. Updates should also include any
anticipated changes in projected groundwater production, local supply production, imported
water deliveries, and retail demands as a result of actual operations to date. When certifying
Monthly In -lieu Treated Deliveries Credit, please mark any box(es) above the month(s) where
OWSE%EC/CONTRADMIPROGRAM FORMS/REPLENISHMENT AND CUP CERTIFICATION 00CUMENTATION.000
251-10
adjustments have been made to Manned operations in Lines (C4), (C5), or (C6). In addition,
mark any box(es) below the Monthly In -Lieu Credit where Actuals to Date have been
determined
q Line C1 - Adjusted Baseline: This line carries forward Santa Ana's Adjusted Baseline
calculated in Line A6.
tai Line C2 - Actual Monthly Production Capability: Santa Ana specifies the actual well
capability available for the month being certified and, as needed, updates projected well
capability for the remainder of the operating period.
1Q Line C3 - Baseline: Spreadsheet calculates monthly Baseline, i.e., the lesser of the
Adjusted Baseline or Monthly Production Capability.
4 Line C4 - Groundwater Production: Santa Ana inputs amount of groundwater actually
produced during the operating period and, as needed, updates projected groundwater
production for the remainder of the operating period.
Line CS — All Other Local Sources: Santa Ana inputs local supplies actually produced
during the operating period and, as needed, updates local supplies projected for the
remainder of the operating period,
I Line Cb - Import: Santa Ana inputs imported water purchased from Metropolitan to
meet retail demand during the operating period and, as needed, updates imported water
projected for the remainder of the operating period.
Q Line C7 — Total Retail Demand; Spreadsheet calculates Santa Ana's retail demand,
i.e., Groundwater Production plus Other Local Sources plus Import.
1.:_A Line C8 - Monthly Underproduction: Spreadsheet calculates monthly groundwater
underproduction, i.e., Baseline less Groundwater Production. If positive, indicates water
being stored, If negative, indicates water being taken out of storage (overproduction),
Q Line C9 - Cumulative Underproduction: Spreadsheet sums monthly underproduction
through each month of the operating period beginning at the end of the operating period
(June).
r�'- Line CIO - Monthly In -lieu Credit: Spreadsheet calculates amount of monthly In -lieu
Treated Deliveries to be certified limited by Monthly Production Capability and Imported
water,
Worksheet 2 - Mont/fly Ceptification for Delivery of In -Lieu Cyclic Storage Wait,)-
Worksheet
aterWorksheet 2 must be submitted by Santa Ana for each month that it wishes to certify In -Lieu
Treated Deliveries. On each certification, Santa Ana must indicate their name, the identity of the
O.OPSEXECICONTIA NYPROORAM FORMSIREPLENISNMENT AND CUP CERTIFICATION DOCUMENTATION.000
251-11
retail agency delivering the water, if applicable, and the month in which the operation occurred.
In addition, Santa Ana must sign and date each certification submitted to Metropolitan.
Santa Ana should use Worksheet 2 to certify In -Lieu Treated Deliveries. In addition, for billing
and crediting purposes, Santa Ana should also certify the service connections through which the
delivery was made and the amount of water to be certified as on each service connection,
Individual lines on this form should be completed as follows:
Line C3 - Baseline: Santa Ana inputs Baseline value shown in line C3 of Worksheet 1,
Line C4 - Groundwater Production: Santa Ana inputs value shown in C4 of
Workshect 1.
Q Line C8 — Actual Underproduction: Spreadsheet calculates underproduction occurring
in the month being certified.
Line C2 — Monthly Production Capability: Santa Ana inputs Production Capability
shown in line C2 of Worksheet 1.
9: Line C6 — Monthly Actual Imported Deliveries: Santa Ana inputs Monthly Actual
Imported Deliveries shown in line C8 of Worksheet 1. The sum of volumes certified by
service connection shall be equal to the input for Monthly Actual Imported Deliveries on
Line C6.
O:OPSEXECICONTRADWROGRAM FORMSIREPLENISHMENT AND CUP CERTIFICATION DOCUMENTATION DOC
251-12
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Monthly Certification For
Treated In -Lieu Deliveries to Storage
Agency Name:
Subagency Name:
In -Lieu
Production (includes In -lieu deliveries), AF/month
Production, AF/month
Underproduction, AF/month
Monthly Underproduction
Monthly Production Capability
Monthly Actual Imported Deliveries
nthly In -Lieu Credit, AF
Cyclic Deliveries to Storage, AF
Agency Signature
(Ca)
(C2)
(C6)
Lessor of(CS),(C2),(C6)
Certification Month:
(C3)
(C4)
(C8)�(C3)-(C4) 0
0.01
Total:
Service Connection #
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Service Connection #
Service Connection # -
Service Connection #
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Service Connection #
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Service Connection #
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251-14
Date