More Tucson Water collaboration on water issues with “stakeholders,” including those in the business community? Definitely yes.

Water conservation mandates such as limiting what days in the week people can spray their outdoor landscaping? Not likely.

Limits on population growth and new development to keep Tucson’s water supply whole? Definitely not.

Those views highlight the reactions of Tucson Water officials to many hundreds of written comments on the city’s newly adopted, long-range water plan. Dubbed One Water 2100, the 118-page document offers a blueprint for how the utility and the City Council that adopted the plan view Tucson’s water future.

The plan’s highlights clearly emphasize getting new water supplies and protecting existing supplies from contamination over conservation. Of 13 policies that the plan labels as high priority, only three  involve new or expanded ways to conserve water. Six advocate finding new supplies such as treating wastewater to drink, while three others advocate policies to insure our water is protected from additional contamination and that existing groundwater pollution is cleaned up.

Favorable, negative responses

Tucson Water greeted greeted a number of written comments from business advocacy groups more favorably than it appeared to respond to many of the others from individuals and conservation advocacy groups.

The utility repeatedly promised to incorporate some of the concerns of those business groups into the final plan and to make sure that they would be consulted when the city moved to draw up a future, formal implementation scheme.

Business groups got about 30 favorable responses to their comments and a handful of negative responses. These groups included the Tucson Metro Chamber, the Southern Arizona Home Builders Association, the Tucson Association of Realtors and the Arizona Multi-Housing Association.

Two conservation groups that submitted comments, the Watershed Management Group and the Tortolita Alliance, got 20 negative response to their comments, almost as twice as many as positive responses.

Generally, the comments didn’t change much of the plan’s substance. The written comments from numerous individuals and advocacy groups were made on an earlier draft of the plan, before the council’s final approval on Oct. 17.

The utility offered detailed, written responses only to written comments from the advocacy groups and to questions asked by the Arizona Daily Star about 11 comments from individuals.

But it also posted a table online that listed more than 300 comments. The table shows that the utility incorporated about 90 of those comments into the One Water 2100 plan. It sent personal responses to another 245 comments without incorporating them into the plan.

The majority of comments incorporated into the plan were technical in nature. They requested things like factual error corrections, changes in emphasis, map colors, word changes, issues with type face or other lesser issues. One successfully sought Tucson Water’s acknowledgement that Tucson’s development and water use has affected supplies used by the Tohono O’odham Nation. Only a handful of those commenters sought major policy changes.

“Supply and demands” crux

In an interview, Tucson Water Director John Kmiec acknowledged that many commenters were interested in “multiple items,” including the relationship between energy and water use and in environmental impacts. But in general, the majority of commenters were focused on water supply and demand, “and they are the two primary drivers” in the plan’s efforts to draw up future scenarios for the city’s water system, he said.

Prior to when the utility received received written comments about the plan last summer, it held workshops, town halls and many other forms of public meetings and also did some interviews with individuals and conducted surveys of people to get their ideas as to what should go in the plan, said Tucson Water spokeswoman Natalie DeRoock. Many hundreds of people participated in those efforts.

Those “stakeholder” comments were more influential because they started at the beginning of a four-year effort to create a plan, starting in 2019, Kmiec said. Written comments came after a draft plan appeared, “where items could be incorporated and adjusted,” he said.

“Focusing on supply and demands, that’s the crux. Local stakeholders helped guide that focus,” he said.

Residents’ suggestions

Here are some samples of written comments, and Tucson Water’s responses:

1. GROWTH AND WATER. Several commenters wanted some action taken to limit population growth and/or development.

Comment: Patricia Rossi wrote, “We are definitely at risk of water shortages, yet building continues. Developers build, take their profits and move on. Residents, businesses and farmers are left with the glass not half full, but almost empty. This is not a new problem. We live in a desert. Wait and see what happens to our local economy, the value of our homes and overall well-being unless the water supply issues are taken seriously.”

Response: Tucson Water says even under the most pessimistic of four scenarios studied for the plan, called “Thirsty Desert,” it still expects there to be enough water to serve all expected population growth by 2100, even with a 50% cut in annual Central Arizona Project deliveries of Colorado River water to Tucson.

2. AGGRESSIVE CONSERVATION. Several commenters argued that the city needs to pursue more aggressive water conservation measures to shore up supplies in anticipation of likely future curbs on Tucson’s CAP allocation. Several brought up items such as time of day limits on outdoor watering, or odd-even day outdoor watering. Such restrictions exist in Denver, Las Vegas and some Southern California cities. 

Response: Tucson Water says conservation is indeed a top priority, and it continually explores and implements measures to ensure the sustainable use of our water resources. Tucson Water acknowledges the importance of proactively addressing water conservation and planning for potential reductions in CAP allocations. “While we already have water-saving measures in place, we remain open to exploring additional strategies and restrictions if they are deemed necessary to safeguard our water supply.”

3. INCENTIVES AND REBATES. A number of commenters said the city should offer more incentives to promote water savings. The city already offers rebates for rainwater harvesting and gray water facilities for homeowners and for low-flow toilets and washing machines. The commenters suggested incentives for replacing grass, still larger incentives for gray water and water harvesting, to repair leaks, to cover existing swimming pools or to replace pools.

Response: The annual implementation plan report to the mayor and council will contain further details about conservation measures.

4. MORE ON REBATES. Some comments favored more general incentives, such as “groundwater conservation incentives.” The Tortolita Alliance suggested incentives for installing “weather-based irrigation controllers,” which it said could save up to 12,500 gallons per year per home.

Response: Tucson Water said, “Tucson Water recently had a temporary smart irrigation controller incentive this spring. The amount of water savings and the overall costs of proposed incentive programs have to be prioritized along with our existing incentive programs. Our program’s capacity to manage new incentives is also limited.”

“As is true for any program, the capacity of the water conservation program is limited by the budget of the Water Conservation Fund and the number of staff working in the program. The budget of the program is determined by the revenues from the Water Conservation Fee paid by our customers. The City is currently developing a rebate program for commercial properties to replace non-functional turf with native and drought-adapted vegetation.”

5. WATER HARVESTING MANDATE. Several commenters suggested the city require rainwater harvesting and gray water use for all non-potable demands, including outdoor landscaping and indoor fixtures such as showers and sinks. .

Response: Mandates for water conservation rules received a medium response priority in the plan, based on surveys and stakeholder comments. A strategy for installing smart meters in homes to save water received the highest survey response and is already in process. The department may explore additional demand opportunities in future years of implementation planning.

6. DATA AND COST-BENEFIT ANALYSES. The Southern Arizona Home Builders Association, the realtors’ association and the multi-housing group asked that the plan both incorporate more factual data to support and prioritize its recommendations, and both recommendations and implemented strategies should contain cost-benefit analyses.

“While properly managing our water is the top priority, the specific actions necessary to do so should bear a close relationship to the cost or impact,” the groups wrote.

Response: “One of the next steps for the One Water 2100 will be a more thorough implementation plan … We will take the above two comments into account as we implement the strategies,” Tucson Water Director Kmiec replied.

7. GO SOLAR? Commentator Betty Beard wrote, “If we get into a situation where we have rolling blackouts, we could have water shortages. Does Tucson Water need to invest more on pumps or its own electricity source like solar?”

Several other commenters suggested covering the CAP aqueduct and other open water sources with solar panels, to reduce evaporation and provide more renewable energy. This month, the Gila River Indian Community announced a $6.4 million contract with the U.S. Army Corps of Engineers to cover part of an irrigation canal with solar panels. Also, California is now financing a $20 million project to cover two sections of aqueduct in its Central Valley with solar panels.

Response: Tucson Water officials didn’t answer Beard’s question. To the second, they said, “Covering the CAP canal with solar panels is a question that should be directed to the Central Arizona Water Conservation District” (which runs the CAP). 

Terry Goddard, president of CAP’s governing board, said, “At CAP we are watching the various pilot projects on canal covering with great interest. Always looking for cost effective ways to save water. As I understand it, relatively little system evaporation comes from the canals. It’s mostly from the lakes.” 

8. WATER LOSSES. A few commenters said Tucson Water needs to do more to reduce the amount of water lost due to “system losses,” such as leaks.

Response: Water loss control is a priority and we are taking active steps to address it. Our utility is committed to the responsible management of our water resources and the reduction of system losses. The utility over the years has developed a water loss control program. This program explores and tests promising technology solutions, to reduce real losses such as system leakage.

9. LOW WATER USE – PROVE IT. Commenter Karl Flessa suggested that the plan include a table to document the plan’s assertion that Tucson has a low gallons-per-person-per-day water use compared to other cities. Can Tucson Water document that Tucsonans use less water than other Western cities?

Response: A Water Research Foundation study in different locations (Denver and Fort Collins, Colorado; Tacoma, Washington; Scottsdale, Arizona; San Antonio, Texas; Toho, Florida; Clayton County, Georgia; Peel and Waterloo, Ontario) found an average of 89 gallons per person daily for total residential water use, both indoors and outdoors. Mesa’s residential gpcd is approximately 110. Tucson’s residential gpcd is is approximately 75. 

10. DAMS ON WASHES. Commenters Jeffrey Howell and Brad Thompson suggested building earthen dams in washes to capture rainwater, to slow water flows during storms, and allow it to more easily replenishes the aquifer.

Response: None. 

11. WATER QUALITY. Julia Fonseca, a retired Pima County environmental planning manager, said that because of the U.S. Supreme Court’s Sackett vs. EPA ruling this year that severely limited the scope of federal Clean Water Act protection of ephemeral streams, Tucson needs to take more aggressive measures to protect local washes and rivers from pollution. The city should, among other activities, work with other entities to strengthen local protections around land-surface disposal of contaminants, she said.

“The whole system of water quality protection needs to be re-examined at the local level to safeguard our underground water supplies in the Tucson and Avra (Valley) Basins,” Fonseca said.

Response: Tucson Water supports Stormwater Protection Plans that would minimize pollution runoff from the community into the watershed.

12. MORE SOLAR. Commenter Christopher Graber said, “Make it easy for many more homes and businesses to have solar panels installed, through further incentives, partnerships, and programs. After ours were installed on our home by Technicians for Sustainability, I couldn’t believe the figures they shared on the long term water savings (via using less TEP coal-based power) — somewhat more impressive even than the energy production/savings. It was estimated that approximately 500 gallons of water would be saved per month and nearly 27k lbs. would be offset per year.”

Response: Commercial and residential solar measures are outside of the scope of the One Water 2100 plan but fits into the city’s climate action plan, Tucson Resilient Together.