Laserfiche WebLink
<br />...- <br /> <br />(4) Active conservation estimates need additional consideration and analysis. <br /> <br />} <br /> <br />Although the work has not been completed. it appears that the SWSI analysis of potential <br />"active" conservation savings also will significantly underestimate 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 conservation <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 Conservation 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 Entities (July 2(03). The report found that several providers had not <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 mban water planning (p,,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 />~ <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 past two years numerous <br />cities throughout Colorado have either modified (or are hard at work analyzing how best to <br />modify) their water rate stmctmes. More and more cities are moving to increasing block rate <br />stroctures and even water budget rate structures (Boulder, Aurora, etc,,). While many of these <br />efforts to make rate stroctures 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 20007 the effect <br />of these recent water rate changes will be missed by the SWSI demand projection analysis. M&I <br />water demand is heavily correlated to the aggressiveness of the rate structure. Furthermore, <br />many other cities will likely consider more aggressive rate stroctures as we move farther into the <br />21st Century. Reassessing water rate stmctures 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 />