Municipal Conservation Programs

Table 7-2 The draft water budget for the Tucson AMA.

AMAs establish conservation goals for each municipal water provider or major agricultural or industrial water user. Large municipal water providers are allowed to choose among four programs to regulate their water use. The total gallons per capita per day (gpcd) program is the base program, under which gpcd goals are set for each provider. If goals are not met, a provider can be fined, although provisions allow water use in very dry years to be balanced with use in wet years. Alternative approaches include:

• Non-Per Capita Conservation Program, which allows water providers having resources to implement conservation programs as well as access to alternative supplies, to implement specific indoor and outdoor water conservation measures as well as education programs instead of meeting specific gpcd goals. To be accepted into this program, providers must demonstrate that they have reduced groundwater use. ADWR monitors the implementation and results of these measures.
• Alternative Conservation Program, which allows providers with an unusually large and growing amount of non-residential water use (e.g., a major new industrial plant) some flexibility in meeting conservation requirements. After limiting annual groundwater withdrawals, providers must meet gpcd requirements for residential users only, while implementing specific conservation measures for non-residential water users. ADWR monitors achievement of residential water use goals and implementation and results of non-residential conservation measures.
• Institutional Provider Program, which allows providers serving primarily non-residential users, including prisons, hospitals, military installations, airparks, and schools, to meet conservation requirements designed specifically for non-residential use. These conservation requirements usually include specific conservation measures for non-residential uses and a maximum residential gpcd rate.

Small water providers, defined by ADWR as serving less than 250 acre-feet of water per year, generally lack the resources to implement conservation programs, and are exempt from meeting specific gpcd requirements. Small providers are required to meet “reasonable conservation requirements,” as established by the director of ADWR.

ADWR has no authority to enforce conservation requirements directly on water users or consumers, only on water providers. This causes problems for some water companies. Regulated by the ACC, private water companies have to assume the initial costs of conservation programs since they are unable to charge their customers for the cost of such programs until the program has been proven effective. Also changes in rate structures to encourage conservation have to go through a rate hearing process before the commission. The ACC does not regulate municipally-owned water companies, but such utilities including Tucson Water, Oro Valley Water and Metro Water go through their own public process before changing water rates.

Agricultural Conservation Requirements

The GMA regulates agricultural water use in several ways. First, no new agricultural land can be developed for irrigation within AMAs and INAs. Only lands which were legally irrigated with groundwater in the five years prior to implementation of the GMA in 1980 may continue to be irrigated with groundwater. Such lands received an Irrigation Grandfathered Right. Only holders of the right may withdraw, receive and use groundwater for growing crops on two or more acres of land within an AMA.

Second, farms are given a maximum annual allotment of groundwater to be used for irrigation. The allotment is calculated by multiplying the maximum number of acres irrigated at any time from 1975 through 1979 by an irrigation water duty. The irrigation water duty is calculated from the annual amount of water per acre that is reasonable to apply to produce the crops that were historically grown from 1975 through 1979. This irrigation water duty is reduced over time as increasing water application efficiencies are required.

In order to allow for variations in weather and changing agricultural market conditions, farms are given a flexibility account, allowing them to accumulate credits for the difference between their actual water use and the groundwater allowance, or borrow from the account if their actual groundwater use exceeds their allowance. Accumulated credits can be used in future years, if needed, to meet conservation requirements. There is no limit to the number of flexibility credits that can be accumulated, and farms are allowed to borrow up to 50 percent of their maximum annual groundwater allotment. Annual groundwater allotments were set near the historic peak of irrigated acreage; thus much more groundwater than is needed is legally available to farmers each year. With irrigation efficiencies increasing on farms and significant amounts of farmland out of production, many farms have accumulated large flexibility account balances.

Industrial Water Use

AWDR assigns conservation requirements specific to each category of industrial water use and encourages substitution of renewable water sources for groundwater.

• Turf-Related Facilities are given annual water allotments calculated for each facility. Water for golf courses is generally limited to 23.8 acre-feet per hole, or enough water for 5 acres of turf per hole at 4.6 acre feet per acre.
• Metal Mines must limit water loss from tailings ponds, recycle water, and reduce water use for dust control.
• Power Plants must achieve a specified number of “cycles of concentration” when they are in full operation. Cycles of concentration is a measure of the degree to which cooling water is recycled. As water is recycled, salt concentrations increase due to evaporation, and fresh water must be added. Maximizing cycles of concentration saves water.
• Large-Scale Cooling Facilities must reach specific concentrations of silica or total hardness in the water used for cooling before the water is discharged and new water is used.
• Sand and Gravel Operations must recycle wash water and implement two additional conservation measures related to dust control and cleanup activities.
• Dairies are given annual water allotments based on assumed water needs. Dairies can alternatively apply to the director of ADWR to be regulated under the Best Management Practices Conservation Program, under which a combination of such practices will be required.