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Recommendations for Pipeline Study |
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Recommendations sent to the Utah Division of Water Resources on issues that should be
addressed in the MWH Lake Powell Pipeline Study May 15, 2007.
1) Ensure objectivity. Ensure that MWH Global does not stack the deck in favor of the
pipeline. Genuine objectivity and fairness should prevail when analyzing water supply
and demand as well as alternatives to the pipeline. Anything less will provide fodder
for critics and community opposition. More importantly, lack of objectivity could lead
water managers away from a more practical plan that could spare Utah major economic
and political hardship.
2) Give local residents a genuine choice. Sponsor community outreach meetings early
on. Genuinely listen to residents rather than tell them what they are to do.
Acknowledge the possibility that a secure water future may not include the pipeline. By
holding open meetings and conversations early, the Division and MWH Global will be
more able to proactively identify community concerns and controversies rather than
being blindsided in the future.
3) Address funding and taxation issues truthfully and openly. Inform the public of the
pipeline’s whole story including its true cost (plus interest and inflation), escalating
impact fees, enabling sprawl, uncertainty of Lake Powell and viable alternatives. Be
aware of local resentment caused by being taxed $1 billion without genuine opportunity
for democratic representation.
Residents should be informed of how much debt would be carried and who would pay
(current versus future residents, including current residents and their children who buy
new homes). What contingencies would be implemented if the growth rate slows and
impact fees are inadequate to cover bond payments? What interest rate will taxpayers
pay?
Pipeline cost estimates should include all associated expenses (e.g. engineering,
surveying, right-of-way acquisition, environmental review and compliance,
maintenance, etc.). Publicizing only construction costs is misleading.
4) Consider the potential financial impact of slower population growth. Pipeline
financing depends heavily on unpredictable future population growth. If the
population grows more slowly than predicted and revenues miss predicted targets, the
Division of Water Resources and subscribing Water Districts would face an unfortunate
choice of raising taxes or allowing the state’s bond rating to drop—causing all project
costs to rise, while encouraging out-migration due to cost of living increases. State
sponsored studies should address this precarious basis upon which the project would
be built and identify contingency plans.
5) Analyze impacts on housing industry and our economy. As impact fees for new
homes and commercial buildings escalate, the relative price of housing would make our
County less attractive to prospective businesses and residents. Cities and taxpayers’
ability to pay for police, fire, roads, schools, sewers, libraries and other essential services
would be strained. Population growth could actually decline as impact fees increasingly
inflate the cost of housing. The subscribing Counties could lose their competitive
advantage to other similar southwestern communities with lower taxes and fees. These
negative results could be avoided by developing less expensive local water sources.
6) Directly address water right issues. Examine and clarify how additional State of
Utah, Washington County Water Conservancy District (WCWCD and agricultural
water rights in the Virgin River Basin could be developed. It appears that Washington
County’s water supply systems could be modified to increase yield and efficiency
through increased system flexibility and water re-use practices. For example, the 150
cubic feet per second capacity of Quail Creek Diversion could be expanded.
Division of Water Rights data shows approximately 18,129 acre feet of privately owned
groundwater rights currently being used for irrigation throughout Washington County.
The Santa Clara River provides 8,341 acre feet of irrigation water rights. Neither of these
resources appear in WCWCD’s potential future water supply studies. No one wants to
see agricultural land converted to housing, but many local farmers have already sold
out. The current trend is clear. MWH Global’s studies should address these issues
directly.
7) Include groundwater analysis. Address the Navajo aquifer’s feasibility as a storage
aquifer and/or back up water source during sustained drought. Examine the WCWCD
claim of 200,000 acre foot storage potential below Sand Hollow Reservoir. Explore the
possibility of other aquifer recharge projects.
8) Facilitate changes to state standards. The Utah Division of Drinking Water Level of
Service standards should be changed to reflect levels established in more water wise
communities throughout the Southwest. The Utah Division of Drinking Water Rule
R309-510 establishes 800 gallons per day for inside use for each dwelling unit with an
average 2.9 occupants. This standard is used in WCWCD studies to determine pipeline
need—0.89 acre foot per dwelling unit, 51% inside, 49% outside including 5000 sq ft of
irrigated landscape.
However, the Division of Drinking Water acknowledges that Rule R309-510 is
established “in the absence of firm water use data.” Numerous indicators—including
WCWCD water use data—suggest that 800 gallon per dwelling is too high for
southwest Utah. Research conducted by MWH Global should be used to establish more
appropriate Level of Service standards for our region.
The 800 gallon standard is significantly less efficient than other arid desert
communities, e.g. Tucson, Albuquerque and Las Vegas. The 800 gallon standard creates
a false sense of water demand when applied to Washington County. MWH Global’s
studies should also acknowledge the shrinking of average lot sizes and the projected
drop in residents per unit to 2.5 by 2040.
9) Compare local water use to similar desert communities. In 2004 Tucson Water (the
metro utility) supported municipal and industrial (M & I) needs for a population of
638,936 with 128,521 acre feet—an average of 177 gallons per capita per day (gpcd). This
includes over 7 million hotel user nights and a significant percentage of second homes.
In 2006, the Albuquerque Bernalillo County Water Utility Authority provided 106,479
acre feet of M & I water for 490,000 residents, an average of 194 gpcd. The WCWCD
Capital Facilities Plan (2005) suggests that 174,000 acre feet would be needed to support
a population of 447,230. This would translate into an average use of 342 gallons per
person per day. Because such comparisons will influence the pipeline’s bedrock
assumptions, they should be included in MWH Global’s needs analysis. See
http://www.westernresourceadvocates.org/media/pdf/FINAL%203%20City.pdf
10) Cost comparison between Pipeline and other alternatives: When all cost data for
the Pipeline is available, MWH should compare the project to other alternatives such as:
improving the efficiency/expanding the yield of existing water projects; conservation
through tiered water fees; restrictions on new lawns and/or buy-back of existing turf;
construction of storm water retention structures for groundwater recharge; acquiring
agricultural water rights for conversion to municipal uses. This comparative cost data
should be displayed in a chart for residents to easily read and understand.
11) Operation and Maintenance costs. In addition to the standard O & M analysis,
MWH Global should estimate the incremental costs of pumping water as the elevation
of Lake Powell rises and falls. For example, what would the added cost be if Lake
Powell is less than 50% full more than 50% of the pipeline’s projected lifetime? What
added costs would occur when electricity for the pumps doubles, triples or quadruples
in price?
12) Risks of inadequate water in Lake Powell. Numerous climate experts, including a
National Academy of Sciences panel, predict that changing weather patterns will likely
reduce snowpack in the Rockies, reduce water supplies to Colorado River reservoirs
and cause increased competition, conflict and litigation among water users. This could
place the proposed pipeline in limbo. In other words, if we put all our eggs in the
pipeline basket, we may come up dry.
After careful study of historical Colorado River flows, the Bureau of Reclamation
recently acknowledged that the Colorado River Compact was based on an overly
optimistic estimate of river flows. The Bureau of Reclamation recently announced a
Colorado River policy shift that reduces water development targets in the Upper Basin
by 25% from 7.5 million acre feet to 6 million acre feet.
The Colorado River Compact currently requires that in times of drought, Upper Basin
states deliver water to Lower Basin states first before taking their own water. (Changes
to this arrangement were recently proposed as “Shortage Criteria” and are currently
being analyzed). In the future, water developments throughout the Colorado River
Basin will further reduce the amount of water stored in Lake Powell. During a
sustained severe drought, it is likely that Utah would not have legal right to withdraw
water for the proposed pipeline until downstream users are satisfied. In this situation,
the expensive pipeline would be dry when the communities that would have grown
dependent upon it would need it most. To avoid this potential catastrophe, the state
would be wise to develop a water system that minimizes its exposure to uncertainties of
Colorado River politics or future severe drought.
Could the Lake Powell pipeline draw water when Lake Powell drops below minimum
power pool elevation? What would the pipeline’s legal priority be?
The MWH Global study should include chart major water rights in the Colorado River’s
upper and lower basins by priority. The study should analyze how upper basin water
shortages would be managed. The public needs to know who will get shorted before
and after the proposed pipeline.
13) Health concerns about Lake Powell water. In addition to reduced storage capacity,
scientists have observed increasing concentrations of chemical pollutants in Lake
Powell when reservoir levels drop. The MWH Global study should analyze the
potential ramifications of increased health risks and water treatment costs associated
with reservoir shrinkage.
Generally speaking, water management contingencies resulting from Colorado River
over-allocation should be addressed in the MWH Global study.
14) Native American water rights. Native American tribes are becoming increasingly
successful in winning their claims to Colorado River water that pre-date the 1922
Compact. Experts estimate that tribes are owed between 3 and 5 million acre feet. As
these claims are satisfied prior to, during or after pipeline construction, less water will
be available for the proposed pipeline.
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