On 4 June 2014, CSPA and a coalition of fishing and environmental organizations submitted comments to the U.S. Bureau of Reclamation (USBR) concerning the proposed cost allocation methodology for the federal Central Valley Project. The comments point out that, among other things, the cost methodology: 1) does not adhere to fundamental principles of economic analysis; 2) is internally inconsistent; 3) unjustifiably shifts costs to taxpayers and 4) perpetuates decades of flawed techniques that have resulted in billions of dollars in direct and indirect subsidies to a relatively few project beneficiaries.
Additionally, since the methodology is actually only a description of a possible cost allocation methodology based upon a flawed historical approach and not a thorough review, it is unclear what the final methodology will be. The letter recommends that USBR revise the proposed methodology and re-circulate it for further public review.