Dropped Water Conservation Alternative

Topic 2: BOR arbitrarily dropped consideration of a viable, reasonable water conservation alternative.

What the Draft EIS says or doesn’t say:

• BOR declares every alternative must provide 86,000 AFY of water (from a “second source” outside the Virgin River watershed), based on their assumptions of 2075 population of 594,660, 240 GPCD, and a “system loss” of 15.4%.
• BOR’s calculations appear to be contrived to show that conservation is not economically feasible; that any “conservation-only” alternative is too expensive.
• The BOR writes, “The DEIS has been prepared in response to the Proposed [Lake Powell Pipeline] Project and does not attempt to compel Washington County residents to modify, change, or curtail their current culture, lifestyle or social expectations.” (DEIS page 15)
• BOR unreasonably asserts that meeting a demand of 176 GPCD, as proposed in the Local Waters Alternative, that relies only on the Virgin River watershed, would require extensive xeriscaping, including converting existing homes, and 100% conversion of agricultural water use to M&I use, which is not the case.
• BOR lauds Washington County for reducing GPCD by 30 percent since 2000, but then expects it will take until 2045 to achieve only modest further reductions (to 240 GPCD) and expects no improvement thereafter.

Why this is a problem:

• The county’s excessive water use—302 gallons per capita per day (GPCD)—is more than twice that of Phoenix and nearly three times that of Tucson.
• In 2015, Washington County used 302 GPCD; by reducing demand just 1% each year we could eliminate the need for 86,000 acre-feet of additional water by 2060, even using BOR’s population projections.
• BOR failed to honestly explore reasonable alternatives such as those relying on water conservation, which were requested by many people during scoping.
• Water conservation alternatives could be implemented incrementally at lower cost and with greater reliability, obviating the need for the LPP altogether; such water conservation practices have been very successful in other western cities.
• Water conservation has been shown by other communities (such as the Southern Nevada Water Authority) to be much less expensive and less risky than investing in water transfers from remote basins and sources.

Commenting guidance:

• The BOR only analyzed a very narrow “No Action” alternative and two pipeline construction alternatives and must consider a reasonable water conservation alternative.
• The BOR must evaluate reasonable alternatives to the proposed pipeline that would avoid or minimize adverse effects. It is not reasonable to reject water conservation alternatives because they do not provide a “second source” of water.
• The BOR must consider a water conservation alternative such as the Local Waters Alternative that would rely on local sources of water and could provide a predictable, stable, less expensive, and incrementally implemented method for satisfying water needs.
• The BOR must expect water use for Washington County that is similar to the current reality in, and achievements by, other southwest communities.
• The BOR must include all future water supplies from municipal and other sources and must use reasonable assumptions—not 100 percent—for agricultural water conversions.
• Just because BOR, as the permitting agency, or the Washington County Water Conservation District (WCWCD), as a water wholesaler, cannot require strict water conservation practices, doesn’t mean that water conservation cannot be implemented by retail water providers to dramatically reduce demand.

Personal Note/Experience:

• Are you a strong supporter of water conservation as an ethic for living in a dry, desert area? Add this commitment to your comments.
• Are you disturbed because the BOR would favor a multi-billion-dollar pipeline when Washington County has among the highest rates of water use in the country? Express that concern in your comments.
• Have you lived in another city/region where water conservation has successfully reduced the average amount of water used per person? Write some comments about that experience.
• Are you a strong supporter of water conservation as an ethic for living in a dry, desert area? Add this commitment to your comments.
• Are you disturbed because the BOR would favor a multi-billion-dollar pipeline when Washington County has among the highest rates of water use in the country? Express that concern in your comments.
• Have you lived in another city/region where water conservation has successfully reduced the average amount of water used per person? Write some comments about that experience.