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

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Since 20 gallons per day per employee is the highest of the ranges in Table 5, RPI used that quantity as the standard for calculate the number of commercial employees that could be supported by 10,000 AFT. Table 6 - Employees Supported by 10,000 Acre Feet Quantity Source /Assumptions Diversion per Day per Commercial Employee 20 Wastewater Treatment and Reuse, Metcalf & Eddy, 2003 Acre Ft. per Commercial Employee 0.015 Assumes 250 business days per year La Plata County Non - Residential Use (AF) 10000 Expert Report for the Opposers, Harris 2007 Projected Unincorporated La Plata County Employees Upstream of Boating Park 651,700 =10,000 / 015 The calculation in Table 6 implies that in the event that commercial activities used 10,000 AF per year, unincorporated La Plata County north and west of Durango would be an intensely commercial urban area with 651,700 employees. It is highly improbable that the unincorporated county north and west of Durango would need water rights for 651,700 employees for two reasons: That is 21 times more employees than the 31,161 jobs in the entire county currently (Bureau of Economic Analysis), which includes 3 municipalities, a tribal government, a ski resort, a golf resort, and a booming natural gas industry. Current La Plata County land use regulations only designate 71.7 acres of land with a non- residential use designation that could accommodate intensive commercial or industrial activities. This calculation excludes the lower impact Tourist Dude Ranch designation which is not intended to develop intensively and areas within reach of water service providers such as the Animas Water Company, and the water service areas for the north county resorts. 72 acres of mostly occupied land will simply not accommodate 651,700 more employees. Table 7 - Acres of Designated Non - Residential Land in Upstream Planning Areas Outside of Water Service Areas Acres of Non - Residential Land North County 29.8 Animas Valley 16.2 West Durango 25.3 Junction Creek 0_5 Total 71.7 Source: La Plata County GIS Summary: The assertion that 10,000 AF could be required for future commercial /industrial development to the north and west of Durango in Table D of the Harris report is not reasonable because: Development of the magnitude of commercial activity necessary in unincorporated mostly residential areas of La Plata County to use 10,000 AF of water is highly improbable, totaling over 651,700 employees. Accommodating this much commercial activity would be difficult since only 71.7 acres of land beyond reach of a water service provider have an eligible designation and most of this is already occupied. La Plata County would have to aggressively pursue commercial development and re- designate massive acreages of residential and agricultural land to non - residential designations.