Rebuttal Report for City of Durango, Case No. 2006CW9

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Table 3 - Minimum and Maximum Residential Units and Water Demand for La Plata County Upstream of The Boating Park Source: Animas River Basin Future Residential Development and Water Demand Study, for City of Durango, prepared by RPI Consulting, 2006. Summary: The results summarized in Table 3 above are based on sound data and careful methodology tailored specifically for estimating future residential water demand. The Harris report offers little in the way of sources, rational, or methodology for estimating future residential development upstream of the Boating Park to be as many as 4,000 units. RPI has established expertise in conducting this type of study and is confident that the results from Animas River Basin Future Residential Development and Dater Demand Study are valid and appropriate for use in this case. LA PLATA HIGHER DENSITY Within the Table D calculations used to justify the recommendation for a 30,000 AF carve -out from the City of Durango RICD, the Harris report includes an estimate of 15,700 AF based on a "market driven approach" of future residential development in the Florida Mesa Planning area of La Plata County. While the Harris report offers no citation it appears that the "market driven approach calculated for the Florida Mesa land use plan" refers to a recent report conducted for La Plata County long range planning entitled Land Use Impact and Suitability Analysis for Florida Mesa Planning District, Four Corners Planning and Design, 2006 (Florida Mesa report). This report was written by a qualified firm using accepted methodology, developed as a long range planning tool. However, the Harris report relies entirely on one highly theoretical long range planning scenario to establish 15,700 AF of future diversion. Presumably, the Harris report is referring to Table 1, pg 19 of the Florida Mesa report as duplicated in Table 4. Table 4 - Duplication of Table from Florida Mesa Report Scenario Minimum Maximum Residential Units 2,550 Units 3,220 Units Water Demand 995 AF 1,256 AF Source: Animas River Basin Future Residential Development and Water Demand Study, for City of Durango, prepared by RPI Consulting, 2006. Summary: The results summarized in Table 3 above are based on sound data and careful methodology tailored specifically for estimating future residential water demand. The Harris report offers little in the way of sources, rational, or methodology for estimating future residential development upstream of the Boating Park to be as many as 4,000 units. RPI has established expertise in conducting this type of study and is confident that the results from Animas River Basin Future Residential Development and Dater Demand Study are valid and appropriate for use in this case. LA PLATA HIGHER DENSITY Within the Table D calculations used to justify the recommendation for a 30,000 AF carve -out from the City of Durango RICD, the Harris report includes an estimate of 15,700 AF based on a "market driven approach" of future residential development in the Florida Mesa Planning area of La Plata County. While the Harris report offers no citation it appears that the "market driven approach calculated for the Florida Mesa land use plan" refers to a recent report conducted for La Plata County long range planning entitled Land Use Impact and Suitability Analysis for Florida Mesa Planning District, Four Corners Planning and Design, 2006 (Florida Mesa report). This report was written by a qualified firm using accepted methodology, developed as a long range planning tool. However, the Harris report relies entirely on one highly theoretical long range planning scenario to establish 15,700 AF of future diversion. Presumably, the Harris report is referring to Table 1, pg 19 of the Florida Mesa report as duplicated in Table 4. Table 4 - Duplication of Table from Florida Mesa Report Scenario New Housing Units 1: Current District Plan 4,295 2:Current Plan with Mixed -Use Nodes 3,272 3: Proposed Revisions to Current Plan 16,599 4: Low Growth 849 5: Market Driven Corridor Plan 41,278 Source: Land Use Impact and Suitability Analysis for Florida Mesa Planning District, Four Corners Planning and Design, 2006, available at La Plata County Planning The development of a market driven corridor scenario by itself is not a reasonable basis for concluding that La Plata County will abandon its current regulations and develop new regulations according to the most intensive of five hypothetical long range planning scenarios crafted by planning consultants.