Topic 3: BOR artificially inflates Washington County’s need for water.

What the Draft EIS says or doesn’t say:

  • BOR bases its purpose and need on unsupported assumptions, including:
    • BOR introduced an arbitrary 15-year “reserve buffer” requirement that calculated water demand for 2060 but calculated for a population in 2075.
    • BOR does not provide evidence for projected “system loss” of 15.4%.
  • BOR does not reconcile their assumptions about Washington County’s future water demand per capita to other areas in the southwestern United States where less water is used.
  • BOR does not fairly consider future technology—for example, new alternatives to reverse osmosis—which might extend our available local water.


Why this is a problem:

  • Many southwest communities have proven that increasing population does not necessarily require increasing water demand, so BOR should not assume that simple growth demands more water.
  • Colorado River water diversions by Nevada, Arizona, and California have been declining, even as populations are increasing; even in St. George, increased population has used less water per capita over the past five years without any severe water conservation efforts.
  • WCWCD claims many millions of dollars were spent to reduce system losses, which they may call “water conservation,” begging the question of why they still forecast a 15.4% loss.
  • Use of the 15-year “reserve buffer” and continuing to use 15.4% “system loss” are contrivances to justify the LPP.
  • BOR has not considered new technologies that can save water or yield more water from existing sources.


Commenting guidance:

  • The DEIS does not adequately characterize future water use; BOR should project future per capita demand that is similar to the current reality in, and achievements by, other states, metropolitan areas, and water districts in the southwest U.S.
  • The DEIS did not identify all potentially available sources, so BOR must quantify the total available water supply and include reasonable increases in yield from sources other than WCWCD’s supply (i.e., cities, irrigation companies, etc.).
  • The BOR must provide a fair and accurate projection to determine how much additional population could be supported by these additional supplies as demand is reduced to levels seen in other, similarly semi-arid, places.


Personal Note/Experience:


  • The history of the LPP has been mired by misinformation as well as a serious lack of transparency. The DEIS continues this pattern with an incomplete and inadequate forecast of water need.  If this is a concern to you, express your displeasure to the BOR.
  • For years LPP proponents have misused data to attempt to distract from the fact that per capita/water use in Washington County is among the highest in the nation. The DEIS continues this pattern. If this irritates you, express your concern to the BOR.