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<br />.~ <br /> <br />RECEIVED <br />APR 0 8 2004 <br /> <br />WESTERN RESOURCE <br />ADVOCATES <br /> <br />OtiIorado V'later CocIS8IVation Board <br /> <br />April 5, 2004 <br /> <br />Rick Brown <br />Colorado Water Conservation Board <br />1313 Sherman Street, Room 721 <br />Denver, CO 80203 <br /> <br />Dear Rick: <br /> <br />We greatly appreciate your cooperation in helping us understand the water demand forecasting <br />component of the SWSI process. The March 23, 2004, memorandum (Memo) from Kelly <br />DiNatale of CDM to your attention provided useful data and explanations on this matter. While <br />working in conjunction with several other environmental organizations in Colorado, we have <br />reviewed the information in this memo. and compiled a short list of comments for your <br />consideration~ The" comments and concerns are as follows: <br /> <br />(1) Municipal and Industrial (M&I) system-wide per capita rates for most counties are <br />quite high and likely inappropriate as the basis for future demand projections. <br /> <br />The assumed county baseline averages in Table 1-1 of the March 24 Memo include many M&I <br />system-wide water use rates that are quite high~ Many of the water use rates listed in Table 1-1 <br />exceed 300 gallons per capita per day (gpcd). These rates are notably higher than other <br />documented 2001 water use data in various Colorado municipalities. A number of the county <br />rates even exceed 400 gpcd, with one rising to 592 gpcd (Pitkin County)~ Water use rates at tlJ.is. <br />level are virtually unheard of throughout the entire Southwest, exceeding some of the regional <br />system-wide averages by a factor of two to three. <br /> <br />In addition to these specific "outliers", the Table 1-1 list as a whole indicates that system-wide <br />M&I per capita water use in Colorado is substantially higher than the regional system-wide M&I <br />averages, as derived from empirical evidence in recent pre-drought years. See, e.g4' Western <br />Resource Advocates, uSmart Water: A Comparative Study of Water Use Efficiency Across the <br />Southwest", 66 (December 2003). For example, the report includes 2001 system-wide per capita <br />rates for four municipal districts in Colorado, as well as a group of other cities throughout the <br />region (see Smart Water page 66, Figure 3,9). <br /> <br />Formerly <br />Land and Water Fund of the Rockies <br /> <br />Colorado Office. 2260 BASELINE ROAD, SUITE 200 · BOULDER, CO 80302 · 303-444-JI88 · FAX: 303-786-8054 · E-MAIL: INFOli)WESTERNRESOURCES.ORG <br />Utah Office. 1473 SOUTH 1100 EASTt SU1TE F · SALT LAKE em, lIT 84105 · 801-487-9911 · FAX: 801-486-4233 · E-MAil; UTAHWWESTERNRESOURCfS.ORG <br /> <br />wWW4westernresourceadvocates. org * <br /> <br />