Colorado WaterWise Council and Indoor BMPs

After what has been a bit of a circumlocutious road for a number of organizations and individuals, it appears that some real progress is about to be made regarding identifying the true costs and benefits of water conservation in Colorado. I am speaking specifically about the Colorado WaterWise Council convening a group from across the state to develop a working list of indoor water conservation best management practices.

For the uninitiated, best management practices (or BMPs) are those activities or programs that entities can implement to improve water use efficiency in their home or business or office. Water providers in Colorado have been developing water conservation plans that list BMPs that they plan to implement for the combined benefit of themselves (water conservation can reduce the costs of developing new water supplies; postpone pricey new capital projects like expanding water treatment and wastewater treatment facilities; etc.) and their customers. However, real water conservation is often driven by individual water customers improving their own water use efficiency because it saves them money - for reduced water use reduces energy costs (for heating hot water) and water and sewer bills.

The State of Colorado has tried repeatedly to develop an understanding of the cost and benefit of water conservation, in part to support the Interstate Basin Compact Commission (IBCC) process, without success. This is not necessarily the State's fault, for good, reliable information regarding the true cost and benefit of improved water use efficiency has only recently been collected in many areas of the state. Denver Water, for example, may have been collecting cost benefit information for perhaps the last 8 to 10 years,... but most locations do not have the resources and therefore programs that Denver Water has had to bring to bear on the issue. Not until recently (the last 2 years or less) has substantial information been collected through "hands on" water audits and meaningful planning efforts to help shed light into the true cost of water conservation.

It is not surprising that the results of recent information collection efforts indicate that thoughtful, focused, meaningful water conservation can be had by any entity that seeks to implement it. The current challenge for improving Colorado's water conservation efforts is more a matter of getting the right information to those that wish to act upon it. Enter the Colorado WaterWise Council and their working group that will be attempting to bring together the most recent information collected statewide, and then packaging it for use by a broad group of water providers and water customers. Let us wish them well.

Proud Day in Highlands Ranch

Centennial Water and Sanitation District (CWSD) has recently succeeded in updating their Water Conservation Plan in accordance with State regulations. Although the exact date of the Plan approval by the State is unclear, the Plan now can be found on CWSD's website (Water Conservation Plan) and on the CWCB weblink site (as of April 3rd), which is indicative of State concurrence that the Plan meets the regulatory requirements.

The Water Conservation Plan update underwent substantial revision since its draft release for public comment in December of 2007. Although public comment was reserved to a handful of letters, CWSD crafted a much improved Final Plan based on the public comment and guidance they received from the Office of Water Conservation and Drought Planning. The initial Water Conservation Plan update was admittedly short on implementation details, which were added and clarified in the later draft and final product.

CWSD has included provisions for residential toilet rebates, pre-wash spray nozzle giveaway for commercial kitchens, residential irrigation system rainfall sensor rebate, non-residential irrigation system rainfall sensor and ET controller rebates and non-residential turf replacement rebate. It is unclear exactly when these measures and programs will be implemented (some time in 2009 according to the Plan), but having them selected for implementation is a tremendous benefit for the water using community and the overall financial operation of the water district (since the cost to implement these measures and programs is a fraction of the cost for replacement water).

One other noteworthy addition to the Final Plan (beyond what was included in the Draft Plan) is a comprehensive evaluation and analysis of non-revenue water (CWSD uses the term unaccounted for water). The analysis provides substantial discussion regarding the measurement and characterization of water losses in the system, and provides an excellent representation of how non-revenue water can be tracked and quantified. One key component of the tracking of non-revenue water is CWSD's meter testing and replacement program. Maintaining accurate and verifiable customer water metering systems is one key component of any appropriate water loss tracking effort.

Now the key challenge for CWSD will be to get the information out to its customers regarding the rebate programs, in conjunction with the District's ongoing educational efforts and water budget billing. It will be most interesting to watch as data is collected to characterize the effectiveness of the program and the change in local water use behavior. Improved water conservation plans are coming to be in many locations across Colorado, and in each locality the challenge will be to collect meaningful data and adjust the Plan implementation in accordance with the feedback provided by water use and customer response. We hope that CWSD can keep the positive energy going behind this important effort given all the fiscal challenges that water providers across the state have had to manage through due to recent events.

Governor's Freeze on Spending and Water Conservation

Here we sit about just over 4 months into the State's 2009 fiscal year, and given existing economic issues and impacts, which are very real, the Governor has put a freeze on various State outlays related to professional services and new hires. We are clearly in difficult, and in many ways, unprecedented times, and this is exactly the kind of executive decision that is needed to keep the State solvent and functioning.

Unfortunately, due to either a legislative or administrative misstep, one important grant fund, the Water Efficiency Grant Program, has been frozen as well. This grant program provides much needed financial support to water providers for purposes of developing and implementing meaningful water conservation plans. The grant program can also be accessed, in some cases, by non-profits for educational purposes. As a non-profit, I am more concerned with water providers not having funding than non-profits, for the following reasons.

To begin with, many water providers, especially those that are special districts (e.g., water and sanitation districts, water districts, municipal districts) operate with a very small staff providing vital water and wastewater services to ther customers. These organizations need financial help to get water conservation programs to be more than some bill stuffers and other general educational activities. They generally need cash to hire a consultant to prepare meaningful water conservation plans and they need cash to implement those plans. The first stages of meaningful water conservation planning and implementation requires that water providers take a hard look at themselves and their customer's water use and management, and to look explicitly at the cost of doing (and not doing) meaningful water conservation. This is labor intensive work that requires a commitment of resources and expertise. Most water providers can get an outstanding plan in place, including cost benefit analyses, for $15 to 20K,... but having this cash can be very challenging to find in already strapped budget thus the importance of the grant program.

Once a plan is in place, water providers need help with implementation. Pagosa Area Water and Sanitation District (PAWSD), for example, is installing an automated meter reading (AMR) program in concert with a meter replacement effort starting this year to help collect better customer water use data. The meter and AMR equipment will support more accurate billing, improved leak detection, and better characterization of non-revenue water. It will also help to better characterize customer water use, especially for seasonal residences and large commercial users. This effort is costing PAWSD hundreds of thousands of dollars with the majority of the costs falling in the next year. They have benefited from a loan to support this capital outlay.

Castle Rock on the other hand utilized Water Efficiency Grant funds to conduct audits of their largest commercial customers, including HOAs that only have irrigation use. These audits identified nearly 80 acre-feet of potential water savings based only on more appropriate outdoor watering practices for 8 irrigation accounts. (At $500 per audit, the savings at these 8 locations may provide Castle Rock with saved water at a cost of about $50 per acre foot.)

Both of these projects illustrate a fact that appears to exist with respect to Colorado's current status of water conservation - we are in a data collection mode in many geographies. We need better data regarding customer water use, non-revenue water, and system leaks before we can launch our most cost effective programs. The Water Efficiency Grant Program is exactly the kind of State support that is needed in many locations to help collect the vital data and allow water providers to identify what water conservation programs will create the most cost effective water savings.

The sooner the Water Efficiency Grant Program becomes available to the water providers, the better our state will be with regard to long term water resource management.

Water Conservation Planning

Kudos to Director Sherman of the Colorado DNR for bringing attention to the long standing issue of Colorado's water providers non-compliance with Colorado Revised Statute 37-60-126. According to the statute, Colorado's water providers should have had "new" water conservation plans filed with the State prepared in accordance with the 2004 legislation (HB-04-1365)beginning July 1, 2006. Two key circumstances have kept the vast majority of those that should have plans from developing new plans and submitting them to the State.

First, some entities created plans in response to the State's first water conservation requirements that came to exist in 1991. In response to the 1991 act, about 70 entities and organizations submitted water conservation plans to the State. Truth be told, only a handful of the plans submitted to the State in the 1990's provide for any meaningful water conservation, in part because the state of the science has moved substantially forward since that time. In addition, the new requirements specified in the 2004 act allow for more meaningful water conservation planning to occur. Specifically what is meant by the phrase "meaningful water conservation?" Meaningful water conservation requires that entities implement water conservation programs which are measurable and verifiable, and create water savings that are sustainable. Very few (a dozen or so) Colorado water providers have water conservation plans that include a rigorous characterization of water supply limitations and expected future demands, quantified water conservation goals that are based upon water supply limitations, and measurable water conservation program outcomes.

Second, there is no penalty for not submitting a water conservation plan to the State, unless an entity is looking to obtain funds from the CWCB Construction Fund account or a loan from the Colorado Water Resources and Power Development Authority. Instead of using a "stick" that would fine or otherwise penalize those entities that are required to have plans but refuse to develop and submit them, the State chose to use a "carrot." The carrot as it exists right now is that only those organizations with approved water conservation plans can receive grant funding from the CWCB water efficiency grant to implement water conservation measures and programs. This grant fund has been used successfully to purchase high efficiency toilets in Northglenn, purchase irrigation control equipment in Castle Pines North, and conduct water conservation workshops all across Colorado training and educating water resource managers, consultants, elected and appointed officials and interested citizens.

To move our water providers, and the customers they support, toward more meaningful water conservation, we need our water resource and district/utility managers to better understand the value of water conservation. For example, in most locations in Colorado, there are dozens of water conservation programs that can produce "saved water" at a cost of less than $5,000 per acre-foot. There are dozens more that can produce saved water at a cost of less than $10,000 per acre-foot. Given that water providers throughout Colorado are looking at replacement water costs (which include the cost of raw water, water transmission and treatment) at values from $15,000 to 45,000 per acre foot, clearly it is in the business interest of all water providing organizations to look seriously into water conservation planning and analyses. Far too often water conservation is neglected (Re: red-headed step child), but those days must be put behind us if our water providing organizations are going to be held to furnishing the best and most cost-effective, sustainable water supply to their customer base. This is the metric that all Colorado citizens are owed and must demand.

Although it is reasonable for the State to wait a bit longer to see if Colorado's water providing entities will rise to the challenge and develop and implement meaningful water conservation plans (which means budgeting and funding meaningful water conservation measures and programs), it may not be far off when the State will be forced to create a legislative "stick" that requires water conservation plans and defines implementation schedules. It will only take one or two failed water development project permits to create the need for legislative pressure, especially if the permitting process is befuddled because of a lack of meaningful water conservation planning. No less than 4 EIS projects are currently progressing in Colorado, and more than half of them have received some negative press due to the lack of demonstrable water conservation efforts by the project proponent(s). This is not the time to disrespect the power and benefit of water conservation as a vital part of any water utilities resource management efforts. It is rather the time for new and progressive measures to be earnestly evaluated and incorporated into the way that Colorado manages its natural resources responsibly and conscientiously.

Interbasin Basin Compact Commission and Water Conservation

The Interbasin Compact Commission (IBCC) of Colorado has made some significant strides related to creating a dialogue and planning for the State's water future. This is of course no small task given the State's history of parochial water development and east slope/west slope animosity. There are dozens of examples of cooperative water projects, but there are numerous other examples of unjust water grabs and unintended consequences related to dam and diversion construction detrimentally impacting environmental settings and local economies to give forward thinking people pause. To this point, the IBCC has taken on, as at least one of its goals, to open the water dialogue to broader interests and more inclusive water uses. Bravo.

Unfortunately, water conservation has taken a back seat in this effort. This is not to say that many water providers and water users in the State do not take water conservation seriously,... many do. But surprisingly, a vast number of the State's water providers - municipalities and special districts - do not appear to take water conservation seriously evidenced by the lack of these entities developing meaningful water conservation plans using the guidelines and requirements set forth in Colorado Statute. Meaningful water conservation plans allow for the setting of water conservation goals and the tracking of successful water savings in a manner that is clearly needed for Colorado to best manage its current and future allocations of water resources in the best and most earnest manner. Without meaningful water conservation plans and the water savings that occur as a result of careful and thoughtful planning, it is difficult for the State to represent its actions in a consistent and consciencious manner to our citizens and to those states that we share in the use of the water transported by our rivers and streams.

Should the State develop more stringent standards and requirements for local water conservation planning and implementation? That is a tricky question, since it is clearly undesirable to create statute that requires local utilities and special districts to commit resources to water conservation that they lack. Due to the TABOR amendments, some utilites and special districts are hard pressed to find general fund monies that could be used for such activities. Although the State has created a nearly $3 million grant program to support local water conservation planning and implementation, pursuing and implementing planning still requires local resources. On the other hand, programs that are based on State regulatory requirements cannot be dismissed by City Councils and Special District Boards as being voluntary and/or unnecessary. Having State requirements can therefore take away the guess work that staff can face at a local level when approaching appointed and/or elected officials.

There is no easy answer. However, it would appear that the IBCC needs to take a more explicit stance reqarding the value and importance of water conservation planning when looking at water development projects that have regional and/or statewide signficance. For example, the Northern Integrated Supply Plan (NISP) has run into opposition due to the potential impact on the Cache la Poudre, and the perception that local municipalities are not planning for and implementing aggressive enough water conservation programs. Interesting that most of the municipalities that would benefit from NISP have yet to complete their water conservation plans. This is not a good thing.

Similarly, the reallocation of Chatfield Reservoir storage from flood pool to water supply storage requires federal permitting and approval. Numerous front range communities stand to gain important storage from this project within an existing storage facility, yet many of the project stakeholders and benefactors have not completed water conservation plans consistent with the State statutes. Given that the Chatfield project has been on the books for over 15 years, and that substantial work has been conducted on the EIS since 2004, it is difficult to understand the mindset of those water providers that have not developed water conservation plans in advance of the EIS preparation and approval process. Some have, but not all.

Isn't getting the entire team to work together in a consistent and beneficial manner one of the goals of the IBCC? It seems like a natural fit. However it has been an unpopular role given that it would require all water users to work as a team and truly share resources, and at times commit resources to the benefit of the larger outcome, not just the needs of the few. It remains to be seen how the overall water needs of the Front Range will be served through the IBCC process. From this writer's perspective, the IBCC is a great idea that will continue to ferment and solidify into the future. However, it may be that unless the IBCC develops strong, and at times unpopular, stands regarding some of the thornier water issues, such as the need for widespread, meaningful (and therefore measurable) water conservation, the overall process will fail. A house divided against itself cannot stand,... and a group of water providers operating in manners inconsistent with the needs of the larger community will similarly fail.

Brighton Water Conservation Plan Receives State Approval

The City of Brighton received written approval from the Colorado Water Conservation Board's (CWCB) Office of Water Conservation and Drought Planning for its Water Conservation Plan. The Plan, which was prepared by Great Western Institute, received high marks from the CWCB and its reviewer/contractor Aqua Craft. Specifically, CWCB indicated that, "The City of Brighton Water Conservation Plan prepared by Great Western Institute is an excellent example of what a conservation plan should be."

The Plan was prepared over about a 6 month period led by City of Brighton Public Works Department staffer, Dawn Hessheimer, who manages multiple water resources projects for the City including augmentation and substitute water supply plans and water conservation. City Planning, Parks and Recreation, Finance, and Public Works Departments all had a hand in supporting Plan development and completion.

CWCB had particular praise for the cost/benefit analyses, and related water savings analyses included in Brighton's Plan. The CWCB has embarked on developing an "Identified Projects and Processes (IPP)" database to track water needs and development into the future, including those related to water conservation. CWCB indicated that the format that Great Western Institute utilized for the City of Brighton, including detailed cost/benefit analyses and assumptions for each selected water conservation measure and program is going to help facilitate the development of the IPP database. Although CWCB will not develop guidelines that are so specific as to require this cost/benefit format, CWCB will promote the use of similar content and information in future Water Conservation Plans since it allows for easy input into the IPP database. This is just the kind of water conservation planning metric that will help the state to quantify "more meaningful water conservation".

Metro Round Table Grant to SMWSA

It is interesting that the Metro Round Table saw fit to provide the South Metro Water Supply Authority $100,500 through the Water Supply Reserve Account (one of the grant programs administered through the Colorado Water Conservation Board), even though the Authority's membership does not comply with the requirements set forth in Colorado statute regarding water conservation planning, and that the State is supposed to consider such compliance when awarding grants. In a State where the Governor has publicly stated that water conservation is his number one priority regarding the creation of future sustainable water supplies, it is alarming that the Authority would be granted funding until such time as its membership met with the basic state requirements.

It can be considered an oversight, if the Authority's membership was small and lacked resources,.. or if the member organizations were in the process of developing meaningful water conservation plans. But, unfortunately this does not appear to be the case. For example, Centennial Water & Sanitation District, which supplies water to nearly 100,000 people in the South Metro area, has developed a draft water conservation plan that was open for public comment early this year. The draft plan that Centennial developed did not meet with the basic requirements of the state statutes, and met with some fairly harsh publicly documented criticism. It is unclear what the status of this draft plan is, but based on this reviewer's read of the draft document, it is not something that Centennial or its customers should be proud of since it does not allow for meaningful water conservation to occur based on the state's definitions.

Meaningful water conservation is obtained through measurable and verifiable reductions in water demand. Centennial claims to have reduced water demand by increasing water rates and implementing a water budget. Although these are good water conservation programs, most of Centennial's reduced water demand occurred prior to its implementation of these two programs,.. and since they implemented increased water rates and the water budget, average per capita water use has increased. Perhaps Centennial Water & Sanitation District, which is led by a Board of Directors that does not represent the customer base that it serves, but is rather staffed entirely by home builders, needs to take a long hard look at its policies and act in a manner that is more in keeping with the needs of the community and the state of water resources management in Douglas County and the Front Range (as evidenced by the handful of communities that do have strong water conservation plans such as Denver Water, Castle Rock, and Colorado Springs).

Given Centennial's actions, and lack of meaningful water conservation, it is surprising and disappointing that the Metro Round Table saw fit to provide funding to SMWSA. If the Authority really wants to be taken seriously, it would seem that it needs to pull together its membership and lead the way with meaningful water conservation. Until such time as this occurs, it would appear that the Authority is going down a path that is not sustainable and will not ultimately provide renewable water supplies to the South Metro area,.. and the State is happy to help them achieve this inauspicious goal.