BOARD01670

• Board Meeting Date: 7/28/2003
• Description: CDP Section - Technical Assistance to Covered Entities
• Board Meetings - Doc Type: Memo

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The CWCB has posted on their website that three criteria are used by Board staff to evaluate water
conservation plans. These are:

1. Each entity shall consider the 9 water-saving measures. Consideration should include the
economic feasibility of implementing these measures and the results of the considerations shall be
set forth in the plan to be adopted by the entity. The plan also must contain a statement of the
entity's 'best judgment of the role of water use efficiency plans in the covered entity's water
supply planning'".

2. Each entity shall make their plans available for the 60-day public comment period. The entity
shall supply the necessary documentation showing that this criterion has been met.

3. A program for the implementation of the water conservation program will be submitted with the
water conservation plan. Implementation should include a process for monitoring and evaluation.

It is the current policy of the CWCB to approve any plan that has the three attributes listed above.
Proof that any plan is implemented or that water conservation is actually occurring within the
jurisdiction of the subject covered entity is not a consideration in the plan approval process.

Current Plans on File
The CWCB currently has 64 approved water conservation plans on file. With few exceptions, all the
plans were received between 1995 and 1997. Given that the governing statute does not require plan
updates, none of the plans on file have been revisited since the initial submittal.

The plans vary greatly with respect to content and comprehensiveness. Some present detailed data
on water supply and use while others do not. Some have detailed analyses of water conservation
measures and how they were selected; others simply mention each measure required by legislation
with a simple yes/no as to its incorporation in the plan.

Overall, only a handful of the plans demonstrate and document a meaningful commitment to water
conservation, even though most of the plans submitted by the covered entities meet the minimum
requirements of the statutory decree. Detailed analyses or information that exceeds statutory
requirements, which is left to the discretion of the water provider, varies greatly from plan to plan.

Summary of Plans on File

Number of Plans 58 covered entities have plans on file with CWCB plus 8
state departments.

Entities with Plans 33 municipalities, 20 special districts, two water
conservancy districts, two water companies, and the
Denver Water Board

The covered entities that have submitted water conservation plans represent/control nearly one half
of the non-irrigation and non-storage deliveries recorded by the State Engineers Office. The
following table provides insight into the amount of deliveries that may be associated with different
threshold levels (in acre-feet) if the statutory requirement of 2,000 acre-feet is considered for change.

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