Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 1 of 43 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 17-cv-2563-REB SAVE THE COLORADO, SAVE THE POUDRE: POUDRE WATERKEEPER, WILDEARTH GUARDIANS, LIVING RIVERS, WATERKEEPER ALLIANCE, and SIERRA CLUB, Petitioners, v. UNITED STATES BUREAU OF RECLAMATION, and UNITED STATES ARMY CORPS OF ENGINEERS. Respondents. EXHIBIT 1 TO PETITIONERS’ MOTION TO SUPPLEMENT THE ADMINISTRATIVE RECORDS   Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 2 of 43 LRB HYDROLOGY & ANALYTICS Comparison of Actual Water Use with Windy Gap Firming Project and Recent Revisions to Projected Water Demands Final Report Lisa Buchanan 5/3/2018 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 3 of 43 Executive Summary This Comparison of Actual Water Use with Windy Gap Firming Project and Recent Revisions to Projected Water Demands report was prepared upon request by members of Save the Colorado. Save the Colorado requested a compilation of actual water use data for Windy Gap Firming Project participants and a comparison of this data with the 2005 water demand projections used for the Windy Gap Firming Project. This Report compares actual water demand data with the Firming Project’s projected water demands for the years when each agency was making their permit decisions (2005-2015). Actual water demand data comes from the Colorado Water Conservation Board’s Water Efficiency Data Portal, which provides public access to actual water demand data for each participating municipality. Data also comes from the publicly available Water Conservation Plans prepared by each municipality. Current water use data were also obtained from Greeley’s Water Department. All of this actual use data was available before the Army Corps of Engineers’ 2017 Record of Decision. All actual water use data in Water Conservation Plans published prior to 2014, as well as 2013 data from the Water Efficiency Data Portal, was available in 2014 before Reclamation’s Record of Decision. Similarly, all of the data leading up to and including the year 2010, including data in Water Conservation Plans published prior to 2010, was available before Reclamation released its Final Environmental Impact Statement in 2011. This Report contains: (1) tables showing each participant’s actual water use; and (2) comparisons of actual water use by project participants to the 2005 water demand projections. The actual use data consistently show that the 2005 demand projections in the Windy Gap Firming Project’s Environmental Impact Statement are overstated. The actual use linear trend lines in the graphs, which extend beyond each agencies’ decision time frame, provide alternative projections that the agencies could have observed based on actual water use data that was available to each agency prior to making their decisions. Overall, the compilation of actual use data in this Report illustrates that the Firming Project’s 2005 water demand projections overestimate Firming Project participants’ water demand, despite the fact that this actual use data was available to both Reclamation and the Corps before each agency made its decision. This Report shows that Reclamation and the Corps could have updated their demand projections with actual use data that was available for the years 2005 to 2015, instead of relying on outdated projections that commenters suggested were overinflated. i Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 4 of 43 Table of Contents 1.0 Introduction………………………………………………………………………………………………………………………. 2.0 Broomfield Water Demand ………………………………………………………………………………………………. 3.0 Erie Water Demand ………………………………………………………………………………………………………….. 4.0 Evans Water Demand………………………………………………………………………………………………………… 5.0 Greeley Water Demand……………………………………………………………………………………………………. 6.0 Little Thompson Water District and CWCWD Water Demand ………………………………………….. 7.0 Longmont Water Demand…………………………………………………………………………………………………. 8.0 Loveland Water Demand…………………………………………………………………………………………………… 9.0 Superior Water Demand ……………………………………………………………………………………………………. 10.0 Fort Lupton, Lafayette, Louisville Water Use Data ……………………………………………………….. 1 7 12 15 18 22 26 30 34 37 List of Tables Table 1-1: Water Demand Data Sources ………………………………………………………………………………….. Table 1-2: Summary Comparison of Actual Versus WGFP Projected Water Demand………………. Table 2-1: Broomfield Water Usage …………………………………………………………………………………………. Table 2-2: Comparison of Broomfield Metered Potable Water Use in WGFP EIS and WC Plan… Table 2-3: Comparison of Actual and WGFP Projected Water Use Broomfield, Colorado………… Table 3-1: Erie Water Use ………………………………………………………………………………………………………… Table 3-2: Comparison of WGFP EIS and Updated WCP: Total and Per Capita Water Use Erie, CO ……………………………………………………………………………………………………………………………………. Table 4-1: Evans Water Use …………………………………………………………………………………………………….. Table 4-2: Comparison of Actual versus WCP Revised and WGFP Demand Projections, Evans, Colorado………………………………………………………………………………………………………………………… Table 5-1: Greeley Water Use ………………………………………………………………………………………………….. Table 5-2: Comparison of Actual, Revised WCP Projected and WGFP Projected Water Demands, Greeley, Colorado …………………………………………………………………………………………………… Table 6-1: Little Thompson Water District Water Use ……………………………………………………………… Table6-2: Comparison of WCP and WGFP Water Demand Projections Little Thompson Water District ………………………………………………………………………………………………………………………….. Table 7-1: Historical Potable Water Use and Updated Potable Water Demand Projections, City of Longmont ……………………………………………………………………………………………………………………. Table 7-2: Comparison of Actual Versus Updated and WGFP Projected Water Demand, Loveland Colorado ………………………………………………………………………………………………………………….. Table 8-1: Loveland Water Use ……………………………………………………………………………………………….. Table 8-2: Comparison of Actual Versus WCP and WGFP Water Demand Projections Loveland Colorado………………………………………………………………………………………………………………….. Table 9-1: Superior Water Use ……………………………………………………………………………………………….. Table 10-1: Lafayette Water Use ……………………………………………………………………………………………. Table 10-2: Louisville Total Treated Water Production…………………………………………………………… 3 4 7 8 9 12 13 15 16 18 20 22 24 26 28 30 32 34 37 39 ii Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 5 of 43 List of Figures Figure 1-1: Comparison of Actual Versus WGFP Projected Demand in 2005, 2010, 2015 ………… Figure 1-2: WGFP Projection: Percent Greater/Less Than Actual Water Use 2005, 2010, 2015… Figure 2-1: Comparison of Actual Versus WGFP Projected Water Demand, Broomfield, Colorado ………………………………………………………………………………………………………………. Figure 2-2: Comparison of Pre-2007 and Post-2006 Actual Water Use, Broomfield, Colorado… Figure 3-1: Comparison of Actual Versus WGFP Projected Water Demand, Erie, Colorado …….. Figure 4-1: Comparison of Actual Versus WCP and WGFP Projected Water Demand, Evans, Colorado ……………………………………………………………………………………………………………………….. Figure 5-1: Comparison of Actual Versus WCP and WGFP Projected Water Demand, Greeley, Colorado ……………………………………………………………………………………………………………………. Figure 6-1: Comparison of Actual Versus WCP and WGFP Projected Water Demand, LTWD…… Figure 7-1: Comparison of Actual Versus WCP and WGFP Projected Water Demand, Longmont, Colorado ………………………………………………………………………………………………………………… Figure 8-1: Comparison of Actual Versus WCP and WGFP Projected Water Demand, Loveland, Colorado ………………………………………………………………………………………………………………….. Figure 9-1: Comparison of Actual Versus WCP and WGFP Projected Water Demand, Superior, Colorado …………………………………………………………………………………………………………………… 5 6 10 11 14 17 21 24 29 33 36 iii Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 6 of 43 1.0 Introduction Historical water demands for towns participating in the Windy Gap Firming Project (WGFP) were compiled from Water Conservation Plans filed at the Colorado Water Conservation Board (CWCB) and from the CWCB Water Efficiency Data Portal. Historical water demand was also provided by Water Departments of Greeley and Evans. Actual water use, reported in these documents, were compared to forecasted water demands noted in the WGFP EIS and updated water demand projections presented in Water Conservation Plans when available. Water use and demand forecasts were evaluated in more detail for eight cities and one water district; Broomfield, Erie, Evans, Greeley, Little Thompson Water District, Longmont, Loveland, and Superior. Available water use data are also compiled for Lafayette, Louisville, and Fort Lupton but not analyzed in detail because of the sparsity of data. Not included in this evaluation are the Platte River Power Authority and the western slope, Middle Park Water Conservancy District. Actual water use or demand did not increase at the same rate as predicted in both the WGFP and in more current revised projections. In the 2000s actual water use flattened out, increased at a much smaller rate than the projections, or decreased. This could be due to a variety of factors including more comprehensive and accurate water use data, implementation of water conservation measures, and increased public awareness after the 2002 drought; all of which tend to reduce the per capita per person water use (gcpd). Per capita use declined for all entities during the 2000s. Water demand projections included as part of the WGFP EIS typically use incomplete data collected in the 1990s to early 2000s. These data are typically not as accurate as more recent data, collected later in the 2000s, because of efforts to: Fully meter city taps. Upgrade old meters which likely introduced measurement errors. Upgrade monitoring capabilities of meters that can relay real time water use information to water resources departments. Meter non-potable raw and non-revenue water use. More accurately define water losses. Coordinate billing and water use categories to avoid billing discrepancies. These metering upgrades have increased the accuracy of actual water use measurements to guide water conservation activities. Per capita water use is declining because of water conservation efforts that include: Water education programs. Water saving appliance replacement and water sense programs for passive water savings. Active monitoring and repair of distribution losses – such as pipe breaks – via use of AMI or AMR technology. Tiered water rate structures that promote water conservation. Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 7 of 43 Active promotion of xeriscape landscaping – may include water sensors to determine the need for water application – for city, residential, commercial, and industrial customers. Watering restrictions on time of day and weekly outdoor water schedules. The effect of the 2002 drought year which prompted long lasting water conservation efforts across the front range of Colorado. Success of water saving efforts is reflected in the steady decline of per capita water use in WGFP participant cities. Updated customer specific per capita use along with land use plans and projected increased population and commercial activity were utilized in the updated water demand projections. Some entities also incorporated anticipated water savings of conservation actions in their projection. Historical reported water use volumes are listed under several categories: Distributed Potable Water – total potable water output from water treatment plants. Metered Potable Water – treated potable water use recorded at customers’ meters. Non-potable raw water – metered raw or untreated water distributed for irrigation. Non-potable reuse water – metered reuse water distributed for irrigation, typically through dedicated transmission piping. Reuse water does not require additional raw water supply but was retained in the total demand since the quantity of water that can be reused to extinction (for instance, Windy Gap water) is variable – though to be accurate reuse water would not increase raw water demand. Exported/Imported Water – potable water supplied to or from entities outside of the town in question. System Water Losses – Potable water lost in the water distribution system is typically calculated as the difference between Distributed and Metered potable water measurements that include both real and apparent losses. Real potable losses represent physical leakage from the potable distribution system. Apparent or non-revenue losses represent incomplete or faulty metering and therefore, billing, metered water that is not billed (e.g. city maintenance of parks), and/or water that is not metered including both authorized (e.g. WTP back-flushing) and unauthorized (e.g. pirated) water use. Total demand or total distributed water equals the sum of both potable and non-potable water use including water losses and non-revenue water. Total demand was also referenced as “Actual Water Use” when comparing to WGFP and revised water demand projections. Gross or total per capita water use (gpcd) was calculated as the total water demand including all customer classes divided by the total number of residents. Residential gpcd, lower than the total gpcd, utilizes only residential and multi-family water use divided by population numbers. Water conservation reports published by individual cities typically focus on potable water systems since projected increases in water demand are based on anticipated population and commercial growth, per capita or per tap potable water use, and land uses. Few of the reports focus on upstream water losses in the raw water delivery system, e.g. between the diversion point for the water right and the Water 2 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 8 of 43 Treatment Plant (WTP). The WGFP EIS included upstream water losses in several cases. To be consistent, when comparing water use to demand forecasts, both potable and non-potable water use was increased by the same percentage loss noted in the WGFP EIS and/or other more recent demand forecasts. Actual shrinkage factors were not determined for each water supply system. Projections in the WGFP EIS substantially over-estimated the future water demand. More recent demand projections published in water conservation plans for many cities, when compared to actual water use in the 2000s, also over-estimate future water needs. In most cases, projected demand increases linearly with time while actual use is variable. The City of Loveland bracketed demand projections between average and more stringent water demand conditions including anticipated passive and active water conservation measures – all of which are lower than WFGP projections and, if active conservation measures are implemented, could result in build out water demand that is less than current water use. Most data presented here were available prior to release of the Bureau of Reclamation Record of Decision in December, 2014 and all data were available prior to release of the Corps of Engineers Record of Decision on May 16, 2017 (Table 1-1). Some of the WC Plans had been published prior to release of the WGFP FEIS in November, 2011. In addition, water use is typically metered and billed on a monthly basis and summarized in annual financial statements. Therefore, water use in individual cities is typically available each year via the billing or water departments. City Broomfield Erie Evans Greeley LTWD Longmont Loveland Superior Table 1-1 : Water Demand Data Sources Updated Water Conservation Plan CWCB Water Efficiency Data Portal AND/OR Supplied by City WCP Years of Data Updated Source Years of Data Demand Projection WCP, 2012 1996 - 2010 CWCB 2013 - 2016 WCP, 2015 2001 - 2013 None WCP, 2009 2003 - 2008 √ City of Evans 2005 - 2016 WCP, 2009 2005, 2007, √ City of Greeley 2012 - 2016 and 2015 2010, 2013 WCP, 2012 2004 - 2010 √ CWCB 2013 WCP, 2008 2000 - 2008 √ CWCB 2013 - 2016 WCP, 2013 2005 - 2011 √ CWCB 2013 - 2016 WCP, 2011 2005 - 2009 √ CWCB 2013 - 2015 Results of this analysis are summarized in Table 1-2 and in Figures 1-1 and 1-2 for 2005, 2010, and 2015. Totals were calculated using only those cities where actual water use data was available in Water Conservation Plans, the CWCB database, or if individual cities provided water use data. Therefore, comparisons of total projected and total actual use between years are not accurate– for instance, in reality, WGFP projected totals increase with time yet total WGFP projections in 2010 (Table 1-2) are less than that noted for 2005. The WGFP EIS was released in 2011 and projections made using up to 2004 data; therefore, 2005 projections are closer to actual water use than 2010 and 2015. WGFP projections 3 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 9 of 43 diverge more from actual use in the latter years indicating that the rate of increase is over-predicted in the EIS. Table 1-2 : Summary Comparison of Actual Versus WGFP Projected Water Demand City 2005 2010 2015 WGFP Actual % WGFP Actual % WGFP Actual 1 1 Projected Use Diff. Projected Use Diff. Projected Use (AF) (AF) (AF) (AF) (AF) (AF) Broomfield 14300 12522 14.2 17300 12819 35.0 19400 12906 Erie 2500 3132 -20.2 4400 3623 21.5 5900 NA3 Evans 4600 3079 49.4 5900 3000 96.7 7000 3187 Greeley 27700 26853 3.2 32400 24635 31.5 37800 25743 LTWD 6000 5550 8.1 7000 6450 8.5 8200 NA3 Longmont 25900 20357 27.2 28100 NA3 NA3 30300 20611 Loveland 14400 12040 19.6 15900 12752 24.7 17800 14232 Superior 2500 1900 31.6 3000 NA3 NA3 3300 1939 Total2 97900 85433 14.59 82900 63279 31.0 115600 78618 % Diff.1 50.3 NA3 119.6 46.8 NA3 47.0 25.1 70.2 47.04 1 Percent difference equals (WGFP Projected-Actual Use)/Actual Water Use or the percent that projected demand is greater (+) or less (-) than actual water use. 2 Totals for each year include only cities where actual water use data were available. For instance, in 2010, projected demand and actual use totals do not include Longmont and Superior and in 2015, Erie and LTWD are omitted from the totals. 3 Data not available in WC Plans, CWCB database, and cities not contacted directly for the information. 4 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 10 of 43 Figure 1-1: Comparison of Actual Versus WGFP Projected Demand in 2005, 2010, and 2015 40000 35000 Water Demand (AF) 30000 25000 20000 15000 10000 5000 0 Broomfield Erie Evans Greeley LTWD Longmont Loveland 2005 Actual Water Use 2005 WGFP Projection 2010 Actual Water Use 2010 WGFP Projection 2015 Actual Water Use 2015WGFP Projection Superior 5 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 11 of 43 WGFP Projection Percent Greater/Less Then Actual Use Figure 1-2 : WGFP Projection Percent Greater/Less Then Actual Water Use 2005, 2010, 2015 120.00 100.00 80.00 60.00 40.00 20.00 0.00 -20.00 -40.00 2005 Percent Difference 2010 Percent Difference 2015 Percent Difference 6 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 12 of 43 Section 2.0: Broomfield Water Demand Actual water use data for Broomfield were obtained from the Water Conservation Plan of 2012 for 1996 to 2010 and from the CWCB Water Efficiency Data Portal for 2013 to 2016. Actual potable and nonpotable water demands are shown in Table 2-1. Table 2-1 Broomfield Water Usage Metered Potable Non-Potable Non-Potable Total Water Use1 Raw Water Reuse Water Demand Year (AF) (AF) (AF) (AF) Data from Broomfield Water Conservation Plan 2012 (Tables II, VII, VIII) 1996 6461 462 NA2 6507 2 2 1997 5961 49 NA 6010 1998 6575 2792 NA2 6854 2 2 1999 7337 346 NA 7683 2000 9264 5032 NA2 9767 2 2 2001 8898 374 NA 9272 2002 7197 15742 NA2 8771 2 2 2003 8218 1574 NA 9792 2004 8147 14122 10532 10612 2005 8752 14122 10532 12084 2006 11392 3503 6623 12054 3 3 2007 9848 350 848 10696 2008 9977 3503 1,1633 11140 3 3 2009 9978 350 1,099 11077 2010 9864 350,3 1,1963 11060 4 Data from CWCB Water Efficiency Data Portal 2013 8853 314 1806 10973 2014 9212 297 2158 11667 2015 9130 295 2127 11552 2016 9999 501 2709 13209 1 Includes metered potable water usage: residential, industrial and commercial, irrigation, parks, out-of-county, and all other potable metered uses as presented in Table II of the 2012 WC Plan. 2 NA=not available; WC Plan (2012) reported metered potable water use only between 1996 and 2005. Raw water use from 1996 to 2004 obtained from WGFP EIS, Table A-5. Broomfield’s reuse system started in 2004: Reuse in 2004 obtained from WGFP EIS, Table A-5. Raw and reuse non-potable data not available for 2005 – assumed equal to 2004 data. 3 Reuse water included as a line item in Table VII of the WC Plan from 2006 to 2010. Non-potable raw water use not presented in WCP, 2012, though raw water is mixed with reuse water in Great Western Reservoir prior to distribution. The 2013 to 2016 average non-potable raw water use - 350 AF – was used to estimate raw water use from 2006 to 2010. 4 Source: CWCB Water Efficiency Data Portal at “cowaterefficiency.com.” “Total Water Demand” above based on “Metered Water Use” reported in the CWCB Data Portal since the “Distributed Water” category in the data portal did not include potable water provided by Denver Water - equal to approximately 2,700, 3,600, 3350, and 3255 AF in 2013 through 2016. 7 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 13 of 43 Broomfield’s potable water is supplied from two major sources of high quality drinking water: (1) treated water purchased from Denver Water and (2) raw water treated at the city’s Water Treatment Facility. These two treated water systems are blended together in the potable water distribution system, WC Plan 2012, page 4. Broomfield’s reuse system became operational in 2004. Reuse water is delivered in dedicated non-potable transmission lines or stored in Great Western Reservoir for later distribution, WC Plan, 2012 page 5. Discrepancy between WGFP and WC Plan Metered Potable Water WGFP EIS water use was consistently higher than that reported in the WC Plan of 2012 (Table 2-2). Table 2-2 Comparison of Broomfield Metered Potable Water Use in WGFP EIS and WC Plan Metered Potable Metered Potable Percent Difference Water Use Water Use Between WGFP EIS WC Plan, 2012 Documents (%) Table A-3 (AF) Table II (AF) 1996 6660 6461 2.9 1997 6630 5961 10.1 1998 7430 6575 11.5 1999 7830 7337 6.3 2000 9670 9264 4.2 2001 9420 8898 5.5 2002 10100 7197 28.7 2003 9390 8218 12.5 Footnote number 7 in Table II of the WC Plan states that “Broomfield switched from an HTE utility billing system to a new Innoprise system in August 2006. There are some discrepancies in the data between the two systems that have not been fully reconciled.” Therefore, the above discrepancies may be due to re-interpretation of the billing data. On page 21 of the WC Plan, it states that, “Total water usage dropped dramatically beginning in 2002, when mandatory water restrictions were adopted in response to the drought.” Therefore, it appears that the high 2002 water use reported in the WGFP EIS was based on old information. The average percent discrepancy between the documents equals 10.2 percent. 8 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 14 of 43 Comparison of Actual Water Demand With WGFP EIS Water Demand Projections Actual water demand shown in Table 2-1 above was adjusted for water losses in Table 2-3 - including 8.5 percent loss in the potable distribution system (WC Plan, 2012 - page 18) plus 5 percent conveyance losses in both the potable and the raw and reuse water systems, consistent with the WGFP EIS. The 8.5 percent potable system loss included: “evaporative loss and reservoir seepage from Glasser Reservoir, line draining, toe drain loss, discrepant meter readings, backwash (potable treatment), loss to wastewater, and unknown losses within the potable system (WC Plan, 2012, page 18).” Except for the data discrepancies noted in Table 2-2 above, these actual and projected water demand numbers should be comparable. Table 2-3 Comparison of Actual and WGFP Projected Water Use Broomfield Colorado Year WC Plan Total Water Demand Plus Losses (AF)1 WGFP Projected Water Demand (AF)2 Year WC Plan Total Water Demand Plus Losses (AF)1 WGFP Projected Water Demand (AF)2 1996 2008 7382 12913 1997 2009 6817 12846 1998 2010 7756 12819 17300 1999 2013 8691 12274 2000 2014 11043 13033 2001 2015 10492 12906 19400 2002 2016 9821 14719 2003 2020 10980 20500 2004 2025 11835 21700 2005 2030 12522 14300 23100 2006 2035 13993 24400 2007 12435 1 Source: WC Plan, 2012 Plus estimated losses – 8.5 % of potable distribution losses plus 5% conveyance losses for total demand (potable with distribution loss and non-potable). 2 Source Windy Gap Firming Project, Final Environmental Impact Statement (FEIS) Chapter 1, Table 1-5. Actual and projected water demands are compared graphically in Figure 2-1. The average 10.2 percent difference caused by re-interpretation of the billing data does not fully explain the diffence in the actual versus WGFP projected demands. WGFP demand projections were 14.2, 35, and 50.3 percent higher than actual water use in 2005, 2010, and 2015, respectively. This reflects a higher rate of change (slope of the trendlne) for the WGFP EIS projections compared to the actual demand trendline slope – as well as variability in the actual water demand data. The WC Plan provided an update to the water demand projections (WC Plan, 2012, Figure 9) but were not tabulated and so were not included here. 9 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 15 of 43 Broomfield anticipated that water conservation measures in its WC Plan would reduce water use by 15.8 percent by 2020 (WC Plan, 2012, page iv). Figure 2-1 Comparison of Actual Versus WGFP Projected Water Demand, Broomfield, Colorado 25000 y = 315.71x - 617643 Water Demand (AF) 23000 21000 19000 17000 15000 13000 11000 y = 314.61x - 619598 9000 7000 5000 1990 1995 2000 Actual Use 2005 2010 2015 2020 2025 2030 WGFP Projected Demand 2035 Actual Use Projection Linear (Actual Use) Linear (WGFP Projected Demand) Linear (Actual Use Projection) 2040 Broomfield is in the process of updating their water conservation plan which will be released later in 2018. Per capita water use has declined since the WGFP EIS was compiled. Table IV of the WC Plan notes a pre-drought (1996 to 2001) average for total gpcd of 173 gallons compared to the post-drought (2002 to 2010) average of 155 gallons. It is anticipated that projected water use in the pending updated WC Plan will show even greater reductions in actual and projected water demands. The WGFP EIS reported an average total gpcd of 188 gallons during the 1990s; however, this figure is likely high due to billing discrepancies noted in Table 2-2. Broomfield water use leveled out after 2006, reflecting this decrease in per capita water use. Figure 2-2 shows the substantial reduction in the rate of increase in Broomfield’s water use after 2006 (water use line slope of 120.8) versus prior to 2007 (water use line slope of 649.7). 10 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 16 of 43 Figure 2-2 Comparison of Pre-2007 and Post-2006 Actual Water Use, Broomfield, Colorado 16000 15000 Water Demand (AF) 14000 13000 y = 649.72x - 1E+06 12000 11000 y = 120.78x - 229953 10000 9000 8000 7000 6000 1995 2000 2005 2010 2015 Pre-2007 Water Use Post-2006 Water Use Linear (Pre-2007 Water Use) Linear (Post-2006 Water Use) 2020 11 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 17 of 43 Section 3.0: Erie Water Demand Actual water use data for Erie were obtained from the Water Conservation Plan of 2015 for 2000 to 2013. The CWCB Water Efficiency Data Portal only reported potable water production and metering, but not non-potable water use, for 2013; therefore, data in the Portal overlapped information in the WCP, 2015, and was not used in this evaluation. Actual potable and non-potable water demands are shown in Table 3-1 for the town of Erie, Colorado. Year Total Potable Metered Use1 (AF) 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 1434 1679 1494 1986 2265 2743 2705 2692 2213 2697 2883 3096 2669 Potable NonRevenue and System Losses2 (AF) (%) 395 326 252 25 268 100 96 196 440 132 82 195 255 21.6 16.3 14.4 1.2 10.6 3.5 3.4 6.8 16.6 4.7 2.8 5.9 8.7 Table 3-1 Erie Water Use NonNonPotable Potable Ditch Reuse (Raw) Water3 Water3 (AF) (AF) 0 0 300* 200* 300* 200* 300* 100* 300* 150* 150* 400* 150* 100* 150* 207 500* 83 500* 121 600* 145 0* 318 300* 197 Total Water Use4 (AF) 1829 2505 2246 2411 2983 3393 3051 3245 3236 3450 3710 3609 3424 Total Water Use Plus 5% Losses (AF) 1920 2630 2358 2532 3132 3563 3204 3407 3398 3623 3896 3789 3595 WGFP Water Demand5 (AF) 2500 4400 1 Source: Erie Water Conservation Plan Update 2015; Table 3-1. Source: Erie WCP Update 2015; Table 3-2. 3 Source: Erie WCP Update 2015: Both Ditch and Reuse Water for 2002 through 2007 interpolated from Figure 3-1. Ditch water also interpolated from Figure 3-1 for 2008 through 2013. Reuse water reported in Table 5-7 for 2008 through 2013. * Estimated. 4 Calculated: equal to sum of the previous 4 columns. 5 Source Windy Gap Firming Project, Final Environmental Impact Statement (FEIS) Chapter 1, Table 1-5. 2 Non-revenue water has been better defined by metering improvements - including increased accuracy of water treatment plant discharges since 2010 and metering of water use for pipeline flushing (WCP, 2015 page 10). This results in a marked decrease in the percentage of non-revenue water over this period of record. 12 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 18 of 43 Total water use noted in the WGFP EIS, and in Table3-1, includes metered potable and a low estimate of non-potable water use. Both were increased by 13 percent in the WGFP EIS to account for water losses – 8 percent for distribution losses and 5 percent for upstream losses. Non-potable raw and reuse water were more accurately monitored and reported in the updated WC Plan (2015). For instance, the WGFP EIS notes 80 AF of non-potable water in Table C-5 as compared to approximately 500 AF of non-potable water in the updated WCP, 2015, for 2002. Per Capita Water Use Total per capita water use, shown in Figure 3-1 of the updated WCP (2015), has declined from 2001 to 2013 (WCP, 2015, Figure 3-1). Erie calculated the gpcd as follows: “Total per capita use was estimated by dividing total system water use (sum of treated water, ditch water and reuse water) by the residential population. System-wide per capita water use spiked in 2002, in part because of the drought and because irrigation using reclaimed water and leased raw ditch water on Vista Ridge began that year (WCP, 2015, page 5).” Per capita water use in Erie declined between 2001 and 2013; averaging 209 gpcd between 2001 and 2006 and 159 gpcd between 2007 and 2013 (WCP, 2015, Figure 3-1). Per capita use presented in the WGFP EIS is inconsistent with the updated WCP, 2015. As shown in Table 3-2, earlier estimates of gpcd were substantially lower than updated figures in the WCP likely due to implementation of better metering of water treatment plant production and of non-potable raw and reuse water since the WGFP EIS was completed. Table 3-2 Comparison of WGFP EIS and Updated WCP: Total and Per Capita Water Use, Erie, CO WGFP Table C-4, page C-5 & C-6 Updated WCP, 2015, Figure3-1 and Table 3-1 Total Water Total Per Capita Use Total Water Total Per Capita Use Use (AF) (gpcd) Use (AF) gpcd 2000 1326 155 2001 1729 180 1829 209 2002 2025 179 2505 276 2003 1786 143 2246 200 Average 164 228 13 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 19 of 43 Comparison of Actual and Forecasted Water Demand Total water demand noted in the WCP is compared to WGFP EIS projected demands in Figure 3-1. WCP total demands noted in Table 3-1 are increased by 5 percent to account for upstream water losses (Table 3-1) to be consistent with the WGFP EIS. Water demand forecasts in the WGFP EIS were calculated using revised population and housing unit projections (WGFP EIS,Table C-7) multiplied by the average 2000 to 2003 total gpcd (164 gallons). Even though WGFP projected demands are calculated using a lower per capita number than per capita figures in the updated WCP (2015), by 2010, WGFP projected water demands (4,400 AF) are 21.5 percent higher than actual water use. In 2005, WGFP projected demands were less than actual water use by 20.2 percent. In the WGFP EIS, buildout is estimated to occur by 2025 at a population of approximately 40,680 and a total water requirement of 8,900 AF including 13 percent losses. The updated WCP did not include revised water use projections; therefore, if actual water use continues to grow as shown in Figure 3-1, it is anticipated that water demand, using the equation for actual water use in Figure 3-1, in 2025 will be 5690 AF, approximately 36 percent lower than projected by the WGFP EIS. Actual and Projected Water Demand (AF) Figure 3-1: Comparison of Actual Versus WGFP Projected Water Demand, Erie Colorado 10000 9000 y = 316x - 630920 8000 7000 6000 5000 4000 3000 2000 y = 140.89x - 279610 1000 0 2000 2005 2010 2015 2020 Actual Water Use (x5%) WGFP Projected Water Use Actual Water Use Projection Linear (Actual Water Use (x5%)) Linear (WGFP Projected Water Use) Linear (Actual Water Use Projection) 2025 14 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 20 of 43 Section 4.0: Evans Water Use Actual water use data for Evans were obtained from the Water Conservation Plan of 2009 for 2003 to 2008. Data from 2009 to 2016 was provided by the City of Evans. Table 4-1: Evans Water Use Metered Non-Potable Total Water Potable Water Demand1,2 Water Demand1,2 1,2 Demand (AF) (AF) (AF) Data from Water Conservation Plan 20091 2003 1951 39 1990 2004 2112 57 2169 2005 2359 124 2483 2006 2416 183 2599 2007 2326 202 2528 2008 2308 202 2510 Data provided by Evans Water and Billing Department2 2009 2044 194 2238 2010 2212 207 2419 2011 2252 231 2484 2012 2404 188 2592 2013 1855 105 1959 2014 2392 161 2553 2015 2354 216 2570 2016 2296 210 2505 Year 1 Source 2003 to 2008: Water Conservation Plan 2009 on CWCB website, Tables 3.5, 3.6, and 3.7. Data from 2005 to 2008 also provided by City of Evans, though with slight discrepancies to data in the WC Plan. 2 Data provided by Andrew Gavaldon, Utility Billing Expert in Evans, CO (10/10/2017) Data reported in gallons converted to Acre Feet (325,851 gallons per AF). “Evans has a 25-year agreement (expires April 2023) with the City of Greeley where Greeley provides treated potable water to Evans through 14 master meters. . . . In the agreement, Evans transfers raw water they own to Greeley in the amount of their projected annual water demand plus 15 percent for shrinkage. . . . Evans water is turned over to Greeley and treated either at Greeley’s Bellevue Water Treatment Plant (WTP) or Boyd Lake WTP according to Greeley’s operation. Most of Evans’ mutual irrigation company rights are available at the Boyd WTP and their CBT water is available at both plants. The City also provides non-potable water supply to dual use customers. The non-potable supplies are delivered via the Evans Town Ditch and through the historical mutual ditch systems (Page 5 WC Plan 2009).” 15 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 21 of 43 Comparison of Actual to WCP Revised and WGFP Demand Projections Actual water use in Table 4-1 above was increased by 24 percent to account for water losses, consistent with loss percentages used in the WC Plan water demand projections, Tables 3-14 and 3-15 on pages 28 and 29 of the WC Plan (2009). Water demand projections noted in the WGFP EIS were increased by 23 percent as distribution losses were estimated at 8 percent instead of 9 percent. Water demand adjusted for water losses for both actual use and projected water demands is shown in Table 4-2 and in graphical format in Figure 4-1. Table 4-2: Comparison of Actual versus WCP Revised and WGFP Demand Projections: Evans, Colorado Year Actual Water Use WCP Revised WGFP Water With Losses1 Water Demand Demand Projection with Projection Losses (AF) (AF)2 (AF)3 2003 2468 2004 2690 2005 3079 4600 2006 3223 2007 3135 2008 3112 2009 2775 3735 2010 3000 3689 5900 2011 3080 3934 2012 3214 4179 2013 2429 4425 2014 3166 4672 2015 3187 4920 7000 2016 3106 5090 2017 5261 2018 5432 2019 5604 2020 5779 8400 2025 6665 9700 2030 7965 11100 2037 9558 13000 1 Total Water Demand in Table 4-1 adjusted for 24 percent losses to both potable and non-potable water uses. Nine percent for both potable and non-potable distribution losses plus 15 percent for Greeley surcharge on potable water and 15 percent ditch losses for non-potable water. 2 Source: WCP, 2009. Loss calculations as for Actual water use (1 above). 3 Source: WGFP, 2005. Both potable and non-potable water demand increased by 23 percent; 8 percent for distribution losses and 15 percent for surcharge and conveyance losses. 16 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 22 of 43 Figure 4-1: Actual Versus WCP and WGFP Water Demand Projections, Evans, Colorado 14000 y = 262.56x - 521910 Water Demand (AF) 12000 10000 8000 y = 208.58x - 415471 6000 4000 2000 0 2000 y = 20.927x - 39078 2005 2010 Actual Use 2015 2020 2025 2030 WCP Revised Projection 2035 WGFP Projection Actual Use Projection Linear (Actual Use) Linear (WCP Revised Projection) Linear (WGFP Projection) Linear (Actual Use Projection) 2040 The WCP identified both potable and non-potable water use and losses by customer categories. Water demand projections assumed a growth rate of 4 percent through 2010, 3 percent through 2020, and 2.5 percent growth to build out in 2037. Non-potable water use was projected to increase by 5 percent per year. Actual water use appears to have leveled out after 2006. Water demand projections over-estimate the rate of demand growth illustrated by the difference in trend line slopes of both projections and the actual use trend line. In 2005, 2010, and 2015, years where actual water use data are available, WGFP projected demands are 49.4, 96.7, and 119.6 percent, respectively, higher than actual water use. The WCP estimates that build out will occur in 2037. The revised WCP projection estimates that total water use in 2037 will be approximately 9,600 AF, 26.2 percent lower than the WGFP water demand projection for 2037. Per Capita Water Use “Per Capita water use has decreased since 1990 due to the City’s current water conservation measures and programs, WCP, 2008 page 16.” Between 1990 and 2002 total and residential gpcd averaged 188 and 157 gpcd, respectively (WGFP EIS, page D-4). Per capita use was stable between 2003 and 2008 averaging 82 gpcd for residential use and 109 gpcd for system wide use. 17 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 23 of 43 Section 5.0: Greeley Water Use Actual water use data for Greeley were obtained from Water Conservation Plans of 2009 and 2015 for years 2005 to 2013. Greeley has not reported in the CWCB Water Efficiency Data Portal; therefore, water use data were requested of and obtained from John Thornhill at the Greeley Water Department for 2012 through 2016. Actual potable and non-potable water demands are shown in Table 5-1 for the town of Greeley, Colorado. Year 2005 2007 2010 2013 2012 2013 2014 2015 2016 Metered Potable Use – Inside Greeley Table 5-1 Greeley Water Use Metered Potable Use – Metered NonOutside Greeley Potable Use (AF) Total Outside Supplied By Greeley Non-Revenue and Water Losses4 (AF) (%) (AF) (AF) 1,2,3 Data from Greeley Water Conservation Plans 2009 and 2015 215002* 50002* 350 1478 15002* 6.5 1 2 20,811 5,500 * 385 1478 1,5002* 6.7 2 2 2 19600 * 4600 * 322 1478 1500 * 7.1 196203 42686 316 13576 8616 4.2 6 2012-2016 Data Provided by City of Greeley Water Department 22455 4780 349 1911 888 3.8 19620 4268 316 1357 861 4.2 18958 4166 302 1151 1194 5.9 19844 4432 305 1544 692 3.4 20551 4563 310 1427 1058 4.9 Total Water Demand 5 (AF) 28552 27800 26335 22,154 25,603 22,154 21,605 22,385 23,346 NA = not available. 1 Source: Table 2 Greeley WC Plan 2009. 2 Source: Figure 7 Greeley WC Plan 2015 - Interpolated from graph. * Estimated. 3 Source: Table 3 Greeley WC Plan 2015. Non-potable water use not included in 2009 and 2015 WC Plans – average of 2012 to 2016 non-potable use incorporated into the 2005, 2007, and 2010 total water demand. 4 Losses calculated as the difference between plant and metered demand in Greeley data = to distribution losses and non-revenue water lost between the treatment plant and customer meters. Percent loss of total potable deliveries equal to Metered Potable Use- Inside Greeley + Water Losses). 5 Total Demand above calculated as sum of previous 4 columns including only that water supplied from Greeley’s water portfolio to Outside City entities. 6 Data Provided by John Thornhill at Greeley Water Department, (11/20/2017) for 2012 through 2016. Inside and Outside Greeley Customers The demand table supplied by the Greeley Water Department on 11/20/2017 lists several outside city entities to which Greeley supplies potable water. Four of these entities, labelled “Outside City #1 (City of Evans), #2, and #3” and “Outside Industrial #1” supply raw water from their own water rights 18 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 24 of 43 portfolio to Greeley for treatment (see City of Evans and personal communication John Thornhill, 1/31/2018). Ninety-three percent of the “Metered Potable Use- Outside Greeley” water was delivered to these four entities in 2012 through 2016 and, to be accurate, is not included in the overall demand for Greeley (equal to 4431, 3952, 3864, 4127, and 4253 AF in 2012 through 2016). In previous years noted in Table 5-1, 93 percent of the “Metered Potable Use – Outside Greeley” was omitted from the Total Demand. Outside entities that supplied their own water to Greeley for treatment were also not included in total demand for Greeley in the WGFP EIS (WGFP EIS, page F-7). The WGFP EIS states: “Three large Greeley customers, the University of Northern Colorado (UNC), Eastman Kodak Corporation (Kodak), and Swift and Company (Swift) provide their own water to the City of Greeley, which Greeley treats pursuant to contracts with each (WGFP EIS page F-7).” Currently Kodak, outside the city, still supplies water for their demand. Since the WGFP EIS was completed, Swift, inside the city, transferred their water right to Greeley’s portfolio: therefore, more recent “Inside Greeley” water use will be higher due to this water rights transfer in combination with general demand increases. UNC, also inside the city, gets potable water from the city but provides its own ditch water for non-potable use (Personal Communication, John Thornhill, 3/11/2017). Statements on UNC potable water seem contradictory. For purposes of this evaluation, potable water supplied to UNC - Inside Greeley, was retained in total water demand. Reuse: Greeley uses reusable effluent from the Greeley Loveland System (Greeley Loveland Irrigation Company, Seven Lakes, and Lake Loveland) and Windy Gap Project water when available to meet return flow obligations and augmentation requirements. Only a portion of Greeley Loveland System water is available for reuse and the amount can vary annually with return flow requirements as determined in Water Court decrees (WGFP EIS, page F-4). Reuse water is not included in total demand numbers in all three documents – the WGFP EIS, WCP, 2008, and WCP, 2015. Non-Potable Water Because the 2009 and 2015 WC Plans do not address non-potable water use, yet non-potable water is utilized in the City of Greeley (WGFP EIS, page F-4), the average of non-potable water use between 2012 and 2016, 1478 AF, was incorporated into the total demand for 2005, 2007, and 2010. Comparison of Actual with WCP and WGFP Water Demand Projections Total measured demands shown in Table 5-1 were increased by 15 percent to account for upstream conveyance losses to be consistent with water demand projections in the WC Plans and the WGFP EIS. WGFP projections were 3.2, 31.5, and 46.8 percent greater than actual water use in 2005, 2010, and 2015, respectively. Percent differences increase with time and reflect the gap between water demand projections that increase over time compared to actual water demands that decreased between 2005 and 2016 (Figure 5-1). Compared to the WCP revised water demand projections, the WGFP overestimates future demands by 10.3, 9.9, and 9.3 percent in 2020, 2025, and 2030, respectively. 19 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 25 of 43 Table 5-2 Comparison of Actual, Revised WCP Projected and WGFP Projected Water Demands Greeley, Colorado Actual Water Use WCP Revised Water WGFP Water Demand 15% conveyance Demand Projections 2 Projections3 1 losses (AF) (AF) (AF) 2005 26853 27700 2007 26100 2010 24635 29437 32400 2012 29443 2013 25477 2014 24846 2015 25743 32413 37800 2016 26848 2020 35927 43900 2025 39816 48500 2030 44135 53500 2035 48926 59000 2040 65000 2045 71500 2050 78500 1 Total Demands noted in Table 5-1 increased by 15% conveyance losses to be consistent with WCP and WGFP Projected Demand calculations. Distribution losses already incorporated into Total Demands of Table 5-1. 2 Source: WCP, 2009 and 2015, page 20, Table 5. Water demands Include 2% treatment losses, 5% distribution losses, and 16% conveyance losses before the plant plus an additional 1,636 AF of new non-potable demand between 2015 and 2035. 3 Source: Windy Gap Firming Project, Final Environmental Impact Statement (FEIS), Table F-5, page F-11. Projected water demands Include 15 % conveyance loss and 5% combined treatment plant and distribution losses. Per Capita Use Per the 2015 WC Plan, page 16: “Figure 6 [WCP, 2015] shows annual metered demand in Greeley from 1997 – 2013 along with the calculated residential gallons per capita per day (gpcd) for each of these years. This figure shows a 23 percent reduction in per capita residential demand, dropping from 156 gpcd in 19972001 to 121 gpcd from 2011-2013. . . . Metered demand is essentially unchanged in sixteen years in spite of a 32 percent increase in population. Clearly, Greeley’s water demand management efforts over the past 17 years have had an impact.” Between 1993 and 2002, total and residential per capita water use averaged 202 gpcd and 194, respectively (WGFP EIS, page F-8). Greeley initiated its universal metering program in the late 1980’s 20 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 26 of 43 with full metering by 1997. Therefore, WGFP gpcd estimates should be comparable to those presented in the WC Plans. Decreased water demand, in which reductions in per capita water use is instrumental, is very apparent in Figure 5-1 and is contrary to both the WGFP and the revised WCP water demand projections. Figure 5-1: Comparison of Actual Versus WCP and WGFP Projected Water Demands, Greeley, CO 55000 y = 1048x - 2E+06 Water Demand (AF) 50000 45000 y = 1024.6x - 2E+06 40000 35000 30000 25000 y = -231.46x + 492933 20000 2005 2010 2015 2020 2025 Actual Use WCP Revised Projections WGFP Projections Actual Use Projection Linear (Actual Use) Linear (WCP Revised Projections) Linear (WGFP Projections) Linear (Actual Use Projection) 2030 21 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 27 of 43 Section 6.0: Little Thompson Water District and CWCWD Water Use The Little Thompson Water District (the District) delivers treated water to several diverse entities in a 300 square mile service area. Water is treated at the Carter Lake Filter Plant (CLFP) co-owned and operated with the Central Weld County Water District (CWCWD) (page 1, LTWD WC Plan, 2012). “The District supplies water to approximately 20,000 people in and around portions of Berthoud, Evans, Firestone, Greeley, Johnstown, Longmont, Loveland, Milliken, Windsor and all of the Town of Mead. In addition, the District delivers water to rural Boulder, Larimer, and Weld County residences, businesses, agricultural, and livestock operations (WC Plan, 2012, page 12).” Water is delivered through 537 miles of pipeline ranging in diameter from 1- to 42-inches (WC Plan, 2012, Table 2.1). Residential customer taps are 96 percent of total taps serviced by the District but consume only 66 percent of the delivered water peaking in the summer months for “landscape irrigation on individual lots as well as in neighborhood open spaces (WCP,2012, page 37).” Master meter contracts with adjacent water providers represent 16.6 percent of water delivered but only 0.2 percent of the taps while 3.9 percent of the total taps are non-residential that require 17.3 percent of water deliveries (Figures 2.4 and 2.5, WC Plan, 2012). Several agreements with other entities are not only for wholesale water service but also for emergency and/or supplemental water (WC Plan, 2012, page 13). As such, water demand for the District can vary depending on water needs of not only individual customers serviced by the District but also population growth, real estate development, and emergency water needs in several different cities and rural areas within their service area. Year 2004 2005 2006 2007 2008 2009 2010 2013 Table 6-1 Little Thompson Water District Water Use Metered Potable Potable Water Demand1,2 Losses1,2 (AF) (AF) (%) Data from WC Plan, 20121 4646 456 9.0 5193 357 6.44 6079 370 5.74 5567 192 3.34 5712 446 7.25 5750 -126 -2.24 5589 861 13.35 Data from Water Efficiency Data Portal2 4534 1141 20.1 Total Potable Demand1,2 (AF) 5102 5550 6449 5759 6158 5624 6450 5675 1 Source: LTWD WC Plan, 2012 Table 3.1, page 39. Source: CWCB Water Efficiency Data Portal – used total distributed water reported in the Portal as total potable demand. Did not include water listed as “Exported.” (Million gallons converted to AF using 325851 gallons/AF) 2 22 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 28 of 43 Water use data compiled in Table 3.1 of the WC Plan (2012) between 2004 and 2010 and for 2013 from the CWCB Water Efficiency Data Portal are shown in Table 6-1 below. Data for years 2014 through 2016 were not entered consistently in the data portal and so could not be used. Though the District aims to start delivery of non-potable water it did not do so at the time the 2012 report was submitted. System Losses “The District implemented more reliable accounting for its losses starting in 2009. Relying on the more accurate accounting, the District identified losses in 2010 greater than 13.3 percent. . . . System losses can be attributed to all unmetered uses including fire flows, flushing lines, illegal taps, pipe leaks, and theft. . . . Regular valve maintenance, pipeline upgrades and prompt leak repair are standard operating procedures [to reduce system leakage]. . . . A SCADA system has been installed throughout the system and is used for real time monitoring (WC Plan, 2012 page 38 and 39).” System losses for 2004 through 2009, reported in Table 6-1 above, likely under-estimate actual system losses due to use of an earlier accounting system. WGFP EIS projections included system wide losses incurred as part of treatment and in delivery of 8 percent. Water Demand Forecast Because of the uncertainty associated with future development in the District service area and in several individual towns, the District notes that: “Projections are intended to be approximate forecasts that demonstrate general trends and [are] not to [be] interpreted as exact targets or absolute predictions of what will occur (WC Plan, page 42).” Water use projections, Table 6-2, were based on five year increments of approved and proposed future developments in the District service area and approximate schedules of construction and tap sales. Both the Windy Gap and WC Plan projections are compared to Actual water use in Table 6-2 and Figure 6-1. 23 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 29 of 43 Table 6-2: Comparison of WCP and WGFP Water Demand Projections Little Thompson Water District Actual Use1 WC Plan Projections2 WGFP Projections3 (AF) (AF) (AF) 2004 5102 2005 5550 6000 2006 6449 2007 5759 2008 6158 2009 5624 2010 6450 7000 2013 5675 2015 5565 8200 2020 6144 9400 2030 7789 12100 2040 10367 15200 1 Source: Table 6-1 above, WC Plan, 2012, Table 3.1 and the CWCB Water Efficiency Data Portal for 2013. Source: WC Plan, 2012, Table3.2. 3 Source: Windy Gap Firming Project, Final Environmental Impact Statement (FEIS) Chapter 1, Table 1-5. 2 Figure 6-1: Comparison of Actual Versus WCP and WGFP Projected Water Demand, LTWD 16000 14000 y = 263.53x - 522679 12000 y = 191.85x - 381269 10000 8000 6000 y = 48.332x - 91193 4000 2000 0 2000 2005 2010 2015 Actual Use 2020 2025 2030 WCP Forecast 2035 WGFP Projection Actual Use Projection Linear (Actual Use) Linear (WCP Forecast) Linear (WGFP Projection) Linear (Actual Use Projection) 2040 2045 24 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 30 of 43 Per Capita Water Use The District’s water conservation efforts have resulted in reduced per capita per day water use as follows: “The 25% reduction in average per tap usage for 2010 compared to 2000 has been attributed to the significant permanent changes in customer usage related to recent drought impacts as well as progressive water rates and conservation incentives (WC Plan, 2012, page 16).” “The District average occupancy of 2.6 people per household was combined with customer water usage to calculate the gallons per capita day (GPCD) for residential customers. Per-capita water use has rebounded slightly since 2004, but remains well below what it was before 2002 (WC Plan. 2012, page 40 and Figure 3.2).” “Through the implementation of water efficiency programs, the District has benefited from a 20% reduction in residential water usage of 215,774 gallons per tap per year in 1996 to a current trend of 171,000 gallons per tap. Including all other industrial, commercial and institutional services, the District has realized a 7% reduction in water usage by all District customers since 1996 (WC Plan Page 64). “ Average residential gpcd throughout the District is shown in Figure 3.2 of the WC Plan. Per capita residential use declined from 200 in 2002 to 176 in 2010. The average gpcd between 2003 and 2010 is 172 gallons. The reduction in gpcd is apparent in Figure 6-1 as the slope of the actual water use trend line is much smaller (48.3) than slopes of either projected trend lines (191.9 and 263.5). Projections made as part of the WGFP EIS exceeded actual water use by 8.1 and 8.5 percent in 2005 and 2010, respectively. WGFP projections exceeded WCP projections by 47.3, 53.0, 55.3, and 46.6 percent in 2015, 2020, 2030, and 2040, respectively. Central Weld County Water District (CWCWD) has not prepared a recent water conservation plan. Total Distributed Potable water was recorded in the CWCB Water Efficiency Data Portal as 9,816 AF in 2013 and 2014 and 11,671 AF in 2016. Inconsistencies in water loss values in two different parts of the data portal (1576 AF versus 1914 AF) for 2016 may indicate that the data are questionable – potentially due to problems in metering water use in the district. 25 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 31 of 43 Section 7.0: Longmont Water Use Actual water use data was obtained from Longmont Water Conservation Master Plan, 2008 as well as the CWCB Water Efficiency Data Portal for 2013 through 2016 (Table 7-1). Longmont revised their water projections as part of the WCM (2008) which are also summarized in Table 7-1. Table 7-1 Historical Potable Water Use and Updated Potable Water Demand Projections City of Longmont Year Metered Exported System Potable Total Longmont Potable Potable Non-Revenue Potable Revised Water Water and Water Water Potable Losses Produced Water Projection (AF) 1,5 (AF) 5 (AF)2,5 (%) (AF) 3 (AF)4 Longmont Water Conservation Master Plan1 2000 17686 2001 13613 3726 21.5 17339 2002 13489 3736 21.7 17225 2003 13123 3080 19.0 16203 2004 12966 2760 17.6 15726 2005 14404 2475 14.7 16879 2006 16217 2662 14.1 18879 2007 15427 27072 14.9 18134 2008 18060 2009 18395 2010 18729 2011 19098 2012 19487 5 CWCB Water Efficiency Data Portal 2013 12424 273 33466 21.2 16043 19819 6 2014 12271 629 2613 17.6 15513 20160 2015 12704 262 30036 20.4 15968 20485 6 2016 14010 304 2697 16.1 17010 20792 2017 21074 1 Source: Longmont Water Conservation Master Plan, 2008 Table 4, Treated Water for residential, commercial, irrigation and City use though “Residential accounts were not fully metered until the end of 2006,” page 13. 2 Source: Longmont WCM Plan, 2008, Tables 4, 5, 6, &7; Potable losses equal the difference between Total Produced and Metered Potable water. Percent losses equal (system losses/total potable demand)*100. Separate estimates of non-revenue and distribution losses for 2007 provided in Table 7 of WCM – distribution losses equaled 8.1% of total production in 2007; the remainder, 6.8%, equal to non-revenue losses. 3 Source: Longmont WCM Plan, 2008, Table 6, Treated Water. 4 Source: Longmont Water Conservation Master Plan, 2008, Table 13 – “Annual Treated Water Demand Forecast Summary” – using the average 103 gpcd rate. 5 Source: CWCB Water Efficiency Data Portal at “cowaterefficiency.com.” 6 Percent potable water loss equal to water loss/(total produced water – export water)*100 - Not available. 26 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 32 of 43 Per Capita Water Use Average residential per capita water use declined from 114 gpcd between 1997 and 2000 to 103 gpcd after year 2000 (WCP, 2008). Average gross per capita water use declined from 210 gpcd between 1997 and 2000 to 186 gpcd between 2006 and 2008 and again to 141 gpcd between 2013 and 2015 (Draft Longmont WC Plan, 2017 available on City of Longmont website). Gross per capita water use was discussed in detail in the Water Demand Evaluation (2012, available on the City of Longmont website) and shows a steady decline since 1970 but particularly between 2000 and 2017. In that document, page 4-2: “It is speculated the reduction in per capita usage and production may be attributed to a variety of factors including, but not limited to, better accounting of water use, increased metering of customers, reduction in water loss, media attention on drought conditions, and increased water conservation practices. Residential water accounts were not fully metered until the end of 2006, and since that time this additional data has allowed for refinement of the estimated unit demand rates used for planning purposes and quantification of the volume of water losses.” Longmont Revised Demand Projections Longmont revised its water demand projections in the WCM (2008) report (Table 7-1). Annual treated water demand forecasts were prepared based on the separate customer categories of water use: residential and multifamily, industrial, small commercial, irrigation, city, and other authorized uses (Section 5.1, page 24). Residential and multifamily customer classes were grouped together for purposes of forecasting, which allowed the forecasting model to predict future residential and multifamily water use based on an average residential per capita water use calculated for this combined customer class. Comparison With WGFP Water Demand Projections The WGFP projections included the City of Longmont’s treated water deliveries plus a 7 percent distribution loss and a 5 percent loss from the treatment plant back to the point of diversion (WGFP EIS, page I-7). Measured distribution system losses were 8.1 percent in 2007 while the remaining potable losses noted in Table 7-1 represent non-revenue water. Therefore, measured potable losses exceed assumed WGFP distribution losses. The City of Longmont has “an extensive network of canals and irrigation ditches that convey raw water to parks, golf courses, schools, and greenways for irrigation” (page 7 of WCM Plan). Raw non-potable water is not metered but was estimated as 1,452 AF based on irrigation of 580 acres to a depth of 30 inches (Table 2 of WCM Plan, 2008). Non-potable water use was reported as 0 AF in the CWCB Water Efficiency Data Portal for Longmont, implying that this water use category continues to be un-monitored by the City. Per the City of Longmont (personal communication with Ken Huson, 3/9/2018), non-potable use for irrigation amounts to between 3,000 and 4,000 AF per year. Actual use and revised projections of potable water demands in Table 7-1 were increased by 3,845 AF, the average of 1990 to 2003 nonpotable demands noted in the WGFP EIS (Table I-6), in Table 7-2 to include non-potable uses. Total 27 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 33 of 43 distributed water and the revised potable water forecasts were increased by 5 percent for upstream conveyance losses to be consistent with the WGFP EIS projections. Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 Table 7-2 Comparison of Actual With Updated and WGFP Projected Water Demand Longmont Colorado Total Actual Water Total Revised Water WGFP Projected Water Demand Projection Demand (+5% upstream loss + (+5% upstream loss + Non-potable) Non-potable ) (AF)1 (AF)1 (AF)2 22415 22051 21931 20858 21400 20357 25900 21568 26200 23668 26700 22886 22808 27000 23160 27300 23511 28100 23898 28500 24307 28800 20690 24655 29200 20134 25012 29500 20611 25354 30300 21706 25676 30700 25973 31100 1 Total Potable Actual and Forecasted Demand in Table 2-1 plus 5% upstream losses in transit to treatment plant plus average of 1990 to 2003 non-potable water use, 3,845 AF, noted in WGFP EIS, page I-6. 2 Source: Windy Gap Firming Project, Final Environmental Impact Statement (FEIS) Chapter 1, Table 1-5 and Appendix I, Table I-5. Adjusted actual water demands and forecasted water demands are shown in Figure 7-1 below. As shown, actual water use has declined between 2000 and 2017 while both forecasts show an estimated increase in water demand. Longmont’s updated forecast for 2017 is 19 percent lower than the WGFP estimate. WGFP projected demands are 27.2 and 47.0 percent higher than actual water use data in 2005 and 2015, respectively. 28 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 34 of 43 35000 Figure 7-1 Comparison of Actual Versus WCP and WGFP Projected Water Demand: Longmont, CO Annual Water Demand (AF) 33000 y = 519.36x - 1E+06 31000 29000 27000 y = 357.6x - 695236 25000 23000 21000 19000 y = -79.24x + 180674 17000 15000 2000 Use 2006 2002 Actual 2004 2008 Projection 2010WCP2012 2014 2016 WGFP Projection Actual Use Projection Linear ( Actual Use) Linear (WCP Projection) Linear (WGFP Projection) Linear (Actual Use Projection) 2018 2020 Longmont prepared an adjusted water demand forecast for build-out in 2048 of 32,730 AF including 27,086 AF of potable and 5,637 AF of raw non-potable water use, a safety factor of 5 percent plus 5 percent losses in conveyance and water treatment facilities (Water Demand Update, 2012, available on the City of Longmont website). This compares to build out water demand forecasts presented in the WGFP EIS of 42,300 AF at build out in 2048. More recent forecasts have the advantage of several years of additional higher quality more comprehensive water use data along with several years of conservation planning and implementation that has resulted in substantial decreases in per capita water use. In addition, as part of changes in the comprehensive land use plan, some areas north of Highway 66 previously identified for Industrial Economic Development uses are now designated as Parks, Greenway, and Open Space. 29 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 35 of 43 Section 8.0: Loveland Water Use Actual water use data for Loveland were obtained from the Water Conservation Plan of 2013 for 2005 to 2011 and from the CWCB Water Efficiency Data Portal for 2013 to 2016. These data are then compared to projections noted in the WGFP EIS (Table 1-5 and Table K-6) and to revised projections in the WC Plan (2013) that include passive conservation and active conservation detailed in the conservation plan (Table 8-1). Year 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total Potable Metered Water Table 8-1 Loveland Water Use Total Potable Non-Potable Non-Revenue and Raw Water Water Losses Total Potable & NonPotable Demand 1 1,2 3 (AF) (AF) (%) (AF) (AF) 1,4,5 Data Obtained from Loveland Water Conservation Plan, 20131 10720 1321 11.0 0 12040 12813 1497 10.5 0 14309 11803 1833 13.4 0 13636 11874 1777 13.0 0 13652 10010 1763 15.0 0 11773 11081 1672 13.1 0 12752 11363 1921 14.5 0 13284 NA NA NA NA NA 5 Data Obtained from CWCB Water Efficiency Data Portal 10592 2412 18.5 0 13004 10693 2166 16.8 800 13659 10923 2509 18.7 800 14232 11864 2213 15.5 0 14077 1 Source: Loveland Water Conservation Plan, 2013, Table 3, page 6. (Conversion factor: 325,851 gallons per AF). Non-Revenue potable water is a mixture of real and apparent losses; due to leaks in distribution piping, unauthorized use, metering inaccuracies such as meter and billing inaccuracies, unmetered uses, and metered but unbilled use, pages 7 – 9 WC Plan, 2013. Percent non-revenue water was calculated as non-revenue water/total demand in 2005 to 2011, 2013 and 2016. Non-potable raw water is not included in the calculation for 2014 and 2015. 3 Non-potable raw water was not used prior to 2013 according to the WCP, 2013. 4 Total Demand equals sum of potable metered, non-revenue, and non-potable water in the distribution system. 5 Source: CWCB Water Efficiency Data Portal at “cowaterefficiency.com.” 2 WGFP Projections Water demand projections noted in the WGFP EIS are provided in Table 8-2. Projection methods are described in Appendix K of the WGFP EIS (page K-9). Average gpcd of 117 gallons were applied to population growth projections up to 127,000 people at build out. An average of 49 gallons per employee per day was utilized to predict increases in commercial, industrial, and city water uses. Nonpotable uses of 850 AF in 2003, increasing linearly to 1,700 AF by 2040, were added to potable water 30 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 36 of 43 supply projections in the WGFP EIS. WGFP projections include system losses of 18 percent for all losses including conveyance, water treatment, and distribution shrinkage, (WGFP EIS, page K-7). Actual measured non-revenue and water losses in the potable system range from 10.5 to 18.7 percent (Table 81) similar to WGFP EIS system losses: therefore, potable water use was not adjusted further for water losses and is comparable to WGFP projections. Concerning non-potable water use: Footnote 2 to Table 1 of the WCP, 2013 states: “Currently, the City only has water demand that is for treated water. In the future, raw water use may be used to irrigate municipal facilities and other large areas of turf, as deemed appropriate.” This contradicts statements in the WGFP EIS that an annual average of 850 AF of non-potable water was used to irrigate most parks and all 3 municipal golf courses. Since the WCP did not discuss non-potable use beyond the footnote, it is assumed that non-potable use was started in or after 2013 as indicated by data in the CWCB Data Portal. WGFP projections still exceed actual use plus 850 AF of non-potable water – in 2005, water demand adjusted by 850 AF is 12,890 AF compared to WGFP demand of 14,400 AF and in 2010 adjusted water demand of 13,602 AF is still much lower than 15,900 AF noted in the WGFP EIS. Revised Loveland Water Demand Projections Loveland revised their water demand projections for metered and non-revenue water use, not including raw non-potable water use, to account for anticipated passive and active conservation savings between 2012 and 2020. These projections are shown in Table 8-2 (Table 11 of the WCP, 2013). “Forecasting was developed for each customer category individually to predictions of monthly and annual water demand. The results of the individual predictions by customer category were summed to estimate total water delivery (i.e., billed water). Total treated water demand was calculated by estimating average monthly non-revenue water (based on the period 2005 to 2011) as a percentage of total treated water (WCP, 2013, Appendix C).” Passive savings are expected to occur as a result of customers replacing toilets, dishwashers and clothes washers with more water efficient models independent of any programs that the City implements. Passive water savings have already been observed in reduced wintertime residential single family water use (WCP, 2013, page 14). Loveland’s active water conservation plan is detailed in Appendix B of the WCP (2013) for potable use and non-potable irrigation and in Sections 6, 7, and 8 of the WCP. Forecasts were completed for two conditions, average water demands (i.e., demands which will occur no more than 5 out of every 10 years) and one standard deviation above average demand condition or less frequent higher water demands (i.e., demand which will occur no more than 8 out of 10 years), both with and without passive water savings and with and without implementation of the active water conservation plan. The WCP projections thus bracket the potential range in water demand conditions with and without active conservation efforts. Table 8-2 compares the total water use (Table 8-1 above) 31 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 37 of 43 with each of the WCP and WGFP EIS demand projections. WCP projections do not include non-potable use. Even if 850 to 1,000 AF of non-potable water use is added to the WCP projections, WGFP projections are still substantially higher than WCP forecasts. Comparison of information in Table 8-2 is also shown in Figure 8-1. Table 8-2: Comparison of Actual Versus WCP and WGFP Water Demand Projections, Loveland Colorado Year Total Potable Projected Projected Projected Projected WGFP & NonAbove Above Average Average Projected Potable Average Average Potable Potable Water Water Use Potable Potable Demand: Demand: Demand Demand: Demand: Passive Passive & Passive Passive & Savings Active Savings Active Savings Savings (AF) 1 (AF)2 (AF)3 (AF)4 (AF)5 (AF)6 2005 12040 14400 2006 14309 2007 13636 2008 13652 2009 11773 2010 12752 15900 2011 13284 2012 NA 14436 14436 12712 12712 2013 13004 14717 14696 12954 12933 2014 13659 148947 145997 13103 12841 7 7 2015 14232 15084 14535 13324 12837 17800 2016 14077 15292 14439 13439 12681 2017 NA 15484 14307 13599 12555 2020 NA 16168 14091 14185 12425 20000 1 Source: Table 8-1 above. Source: Loveland Conservation Plan, 2013, Table 11, page 41 - assumes above average demand conditions with passive water savings but without the proposed active conservation plan. 3 Source: Loveland Conservation Plan, 2013, Table 11, page 41 - assumes above average demand conditions with passive water savings and implementation of the proposed active conservation plan. 4 Source: Loveland Conservation Plan, 2013, Table 11, page 41 - assumes average demand conditions with passive water savings but without the proposed active conservation plan. 5 Source: Loveland Conservation Plan, 2013, Table 11, page 41 - assumes above average demand conditions with passive water savings and implementation of the proposed active conservation plan. 6 Source: Windy Gap Firming Project, Final Environmental Impact Statement (FEIS) Chapter 1, Table 1-5. 7 Projected water demand should be compared to the sum of metered and non-revenue water (minus raw water): equal to 12,859 AF and 13,432 AF in 2014 and 2015, respectively 2 WGFP projected water demands are 19.6, 24.7 and 25.1 percent higher than actual water demands in 2005, 2010 and 2015, respectively. Actual use in 2013 and 2014 is similar to the WCP projection for average conditions with passive savings only. In 2015 and 2016, actual water use is more similar to the above average demand condition with both passive and active conservation savings. WGFP EIS projections exceed all other values. It is interesting to note that the trend line for actual demand, the 32 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 38 of 43 above average demand conditions with passive and active conservation, and the average demand condition with passive conservation only, all converge on one point in 2020. Implementation of the conservation plan would stabilize water demand at or below current levels in Loveland. Figure 8-1: Comparison of Actual Versus WCP Revised and WGFP Demand Projections, Loveland Colorado 20000 y = 374x - 735650 19000 Water Demand (AF) 18000 17000 y = 210.85x - 409767 16000 15000 14000 13000 12000 y = 84.6x - 156765 y = -54.135x + 121809 11000 10000 2005 2007 2009 2011 2013 2015 2017 Actual Use LV Above Avg Projection - Passive LV Above Avg Projection - Passive and Active WGFP Projections LV Avg Projection - Passive & Active LV Average Projection - Passive Actual Use Projection Linear (Actual Use) Linear (LV Above Avg Projection - Passive) Linear (WGFP Projections) Linear (LV Avg Projection - Passive & Active) Linear (Actual Use Projection) 2019 33 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 39 of 43 Section 9.0: Superior Water Use Actual water use data for Superior was obtained from the Water Conservation Plan of 2011 for 2005 to 2009 and from the CWCB Water Efficiency Data Portal for 2013 to 2015. These data are then compared to projections included in both the WGFP EIS (Table 1-5 and N-7) and Superior’s updated water conservation plan of 2011 (Table 14). In the WGFP EIS, build out was predicted in 2014 – EIS projected water demands remain constant at 3,300 AF from 2014 onward. In the 2011 WCP, water use was projected to increase to 2,583 AF by 2020 (Table 14 WCP) approximately 28 percent below build out water use projections in the EIS. Actual and projected water demands are compiled in Table 9-1. Year Total Produced Potable Water (AF)1,5 2005 2006 2007 2008 2009 2010 1338 1591 1550 1589 1380 Table 9-1 Superior Water Use Total Potable NonNonTotal Metered System Potable Potable Distributed Potable Water Raw Reuse Water Water Losses Water Water (AF)1,5 (%)1,5 (AF)2,3,5,6 (AF)2,3,5,6 (AF) 4 Data from Superior Water Conservation Plan, 20111 1306 2.4 5622 combined 1900 1451 8.8 11002 combined 2691 2 1361 12.2 751 combined 2301 1341 12.3 4403 3543 2383 3 3 1205 11.1 440 175 1995 WC Plan Projected Water Demand (AF)7 WGFP Projected Water Demand (AF)8 2343 2500 2600 2700 2800 2900 3000 2426 2454 2481 3200 3300 3300 5 2013 2014 2015 1341 1364 1384 1221 1234 1216 Data from CWCB Water Efficiency Data Portal 8.9 3606 6286 2329 6 6 9.5 131 394 1889 12.1 4636 926 1939 1 Source: Superior WC Plan, 2011 Table 11; Percent water loss equals (Produced minus Metered Potable water)/Produced water. Water losses include “unbilled authorized uses, unmetered uses, leaks, meter inaccuracies etc.” (WCPlan, 2011 page 17). Average of 2007 to 2009 potable water losses are 11.86%. 2 Non-potable water noted in the 2011 WC Plan combines metered, billed, WWTP reuse and raw water, excluding non-potable water losses. Total non-potable use was calculated as the difference between “Annual Potable” and “Annual Total (Potable+Non)” columns in Table 5 for 2005 to 2007. 3 Source: Superior WC Plan, 2011, Table 6, equals the total distributed non-potable water. Values compare to 766 and 550 AF of metered non-potable water (Table 5) and 3.5% and 10.6% non-potable losses in 2008 and 2009, respectively. 4 Total Distributed Water equals sum of total produced potable water plus raw and reuse non-potable water. Water losses upstream of the city distribution system not included. 5 Source: CWCB Water Efficiency Data Portal at “cowaterefficiency.com.” Percent potable water losses equal (potable water loss reported in the database/total produced potable water). 6 Source: CWCB Water Efficiency Data Portal; equal to total distributed non-potable raw and reuse water including losses. Metered non-potable water use data not utilized due to inconsistencies. 7 Source: WC Plan, 2011, Table 14, including water losses. *= predicted value for 2010. 8 Source: Windy Gap Firming Project, Final Environmental Impact Statement (FEIS) Chapter 1, Table 1-5 and Appendix N, Table N-7. 34 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 40 of 43 WGFP – Appendix N Water requirements noted in Tables N-5 to N-7 of the WGFP EIS were adjusted by 2 percent for distribution losses within the city and 3 percent for losses accrued between the point of diversion and the treatment plant (page N-6). Actual measured potable losses between 2005 and 2013 and estimated non-potable system losses in 2008 and 2009 (see footnote 3 above) are considerably higher than loss percentages used in the WGFP EIS and yet WGFP water use projections still exceed actual water use. GPCD was not used to project water demands in the WGFP EIS. Instead, use factors were based on actual 2002 use per type of water customer. WGFP water use projections are shown in Table 9-1 above and Figure 9-1 below. Updated Water Use Projections Table 14 of the Water Conservation Plan, 2011, predicts future potable plus non-potable water use in Superior from 2010 through 2020 calculated using methods presented in Section 2.6 of the Water Conservation Plan – including use of the most recent 2005 to 2009 water use data for gpcd or gptd (gallons per tap per day) estimates of residential and commercial water use, respectively. Non-potable and non-revenue water use data from this time period were used to estimate the average daily water use per non-potable irrigation connection and the percentage of non-revenue water. The above averages were combined with population growth estimates to revise Superior’s projected water use through 2020. Per capita residential water use averaged 113 gallons between 2005 and 2009. Total gpcd averaged 177 gallons over this time period. Actual use, noted in Table 9-1 above, is compared to WCP and WGFP projections in Figure 9-1. WGFP projected demands were 31.6 and 46.9 percent higher than actual water use in 2005 and 2015, respectively. Build-out was predicted to occur in Superior in 2014 when water demand leveled out at 3,300 AF (Figure 9-1). Under the revised projections, water demand is predicted to continue increasing past 2020. In 2020, the WGFP projected demand of 3,300 AF is 27.8 higher than the revised projection of 2583 AF (WCP, 2011, Table 14). 35 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 41 of 43 Figure 9-1 Comparison of Actual Versus WCP and WGFP Projected Water Demand: Superior, Colorado 3500 3300 3100 Water Use (AF) 2900 y = 25.382x - 48668 2700 2500 2300 2100 y = -2.3261x + 6920.7 1900 1700 1500 2005 2007 2009 2011 Actual Use WGFP Projections Linear (Actual Use) Linear (Actual Use Projection) 2013 2015 2017 2019 WCP Projections Actual Use Projection Linear (WCP Projections) 36 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 42 of 43 Section 10: Fort Lupton, Lafayette, and Lousiville Water Use Data Fort Lupton Though Fort Lupton prepared a WC Plan in 2007, historical use was not documented, potentially due to measurement problems at the time. Potable water use, 1674 AF, is reported for 2014 in the CWCB Water Efficiency Data Portal: however since groundwater wells supply a substantial amount of raw water for irrigation and industrial uses (WC Plan, 2007), the data in the Water Efficiency Data Portal are considered incomplete. Lafayette A Lafayette Water Conservation Plan was submitted in 2008 and updated in 2010, however, only the 2008 potable metered water demand (4,176 AF) was presented in Table 3 of the WC Plan. All other demand figures were presented as gallons per capita per day (GPCD), not total volumes, and so could not be compiled here. Metered water use for Lafayette was obtained from the CWCB Water Efficiency Data Port for 2013 through 2016. Distributed potable water for 2014 to 2016 was at or near zero, potentially due to sourcing potable water from outside the city; therefore, potable metered water use listed in the database was used here to represent total distributed potable water in 2014 to 2016. Year 2013 2014 2015 2016 1 Table 10-1: Lafayette Water Use Metered Potable Non-Potable Raw Potable Water Use1 Use1 Loss1 (AF) (AF) (AF) 3804 175 598 3904 154 0 3872 0 0 4330 0 0 Total Demand1 (AF) 4577 4058 3872 4330 Source: CWCB Water Efficiency Data Portal at “cowaterefficiency.com” Because of data inconsistencies in 2014 to 2016 these data may not be accurate. Table 1-5 of the WGFP FEIS estimates water demand in 2015 for Lafayette as 6,500 AF. 37 Case 1:17-cv-02563-REB Document 33-1 Filed 05/03/18 USDC Colorado Page 43 of 43 Louisville Year 2000 2001 2002 2003 2004 2005 2006 2007 2008 Table 10-2: Louisville Total Treated Water Production Total Potable Estimated Year Total Potable Production Water Production 1 3 (AF) Demand (AF)2 (AF) 4800* 2009 3593 4600* 2010 3694 3400* 2011 3820 3800* 2012 4239 3300* 2013 3506 3900* 5000 4300* 4100* 4000* Estimated Water Demand3 (AF) 5300 1 Source: Figure 2 of Louisville WC Plan, 2015. * Values were estimated by interpolation of Figure 2. Source: Table 5 of Louisville WC Plan, 2015. 3 Source: Windy Gap Firming Project, Final Environmental Impact Statement (FEIS) Chapter 1, Table 1-5. Data reported in gallons converted to Acre Feet (325,851 gallons per AF). 2 Metered water demand was not reliably measured in Louisville’s water supply system prior to 2012 because of accounting errors. The water accounting system was improved in 2012, therefore, metered water use and losses are more accurate starting in 2013 (WC Plan, 2015, Table 5 and 6, page 2-5). Because of these inaccuracies, noted in the WC Plan, the summary table above only includes total treated water production. The WC Plan, 2015, presented tabular data from 2009 to 2013 and graphical data from 2000 to 2013. Total water production for years 2000 to 2008 were interpolated from graphics. 38