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<br />(4) Active conservation estimates need additional consideration and analysis. <br /> <br />Although the work has not be~n completed, it appears that the SWSI analysis of potential <br />'~active" conscivation savings ~lso will significantly unclerestimate the' true potential' .of "active <br />water . conservation. On page '9 of the Memo, the explanation that -follows the'definition"'of <br />"active" conservation states that active savings estimates will be based on various co.nservation <br />plans that were submitted and approved as part of the requirements of the Colorado Water <br />Conservation Act of 1991. <br /> <br />We feel this doesn't go nearly far enough. Contractors for the Conse~ation Office of the <br />Colorado Water Conservation Board analyzed the water provider conservation plans on file as of <br />2003~ See Bouvette Consulting and Pinkham Consulting, Draft Strategy for Providing Technical <br />Assistance to Covered Ent_i~i~s (July 2003). The report found th~t several providers., ~ad ~ot <br />submitted conservation plans (p.5), "only a handful of the plans demonstrate and docUment a <br />meaningful commitment to water conservation" (p. 3), and that Colorado lags behind other <br />western states in the. efficacy of its urban water planning (P~4)4 Through a similar review of <br />plans extant as of 2002, Western Resource Advocates found that a large percentage of the plans <br />do not sufficiently or effectively address water conservation potential in the respective urban <br />areas. Many of these plans are very weak and reactive in nature. <br /> <br />If the active conservation alternatives in the SWSI process are based on these plans, Colorado's <br />true potential for conservation savings will be grossly understated. One possible remedy to this <br />situation is to use a thorough conservation plan (e.g. Denver Water) as a baseline model. for the <br />analysis in all counties. <br /> <br />(5) The significant importance of water rate structures. <br /> <br />The SWSI methodology appears to consider water rate structures as an "active" conservation <br />measure, and thus will assume water rate structures as a supply alternative rather than a <br />contributor to demand reduction. We feel that this approach will yield a notably overstated <br />projection of future M&I, demand in Colorado. As you know, in the pa,~t two. y~~s numerous <br />cities throJ.&llQqLCQ!orado have eithe~ modified (or hre hard at w9rli::!1!alYzi!l.i~Qw best to <br />modify) their water rate structures. More and more cities are moving to increasing block rate <br />structures and even water budget rate structures (Boulder, Aurora" etc.). While many of these <br />efforts to make rate structures' more aggressive were catalyzed by. the 2002 drought, most of <br />these cities are considering long-term rate structure changes as a way to develop sufficient <br />revenues and to instill a conservation message, into the rates and minimize system demands in the <br />future. <br /> <br />Since the SWSI demand projections will be based on M&I water use data from 2000, the effect <br />of these recent ~ater rate changes will be missed by the SWSI demand projection ana]y~~s. M&I <br />water. demand is heavily, correlated to the aggressiveness of the rate structure. Furthe~ore, <br />many other cities will likely consider more aggressive rate structures as we move farther into the <br />218t Century. Reassessing water rate structures is becoming a trend throughout the region, as <br />water managers and public officials are starting to realize that water rate structures serve as a <br />core component of any conservation effort. To suggest that modifying water rate structures is <br />