HomeMy WebLinkAbout04.15.2019 WRAB PacketWATER RESOURCES ADVISORY BOARD MEETING
MEETING DATE: Monday April 15, 2019
MEETING TIME: 6:00 p.m.
MEETING LOCATION: Municipal Services Center, 5050 Pearl St., Boulder, CO 80301
Agenda Highlights:
1. Call to Order (6:00 p.m.)
2. Approval of March 18 meeting minutes (6:01 p.m.)
3. Swearing in of new member (6:05 p.m.)
4. Election of Chair, Vice Chair and secretary (6:06 p.m.)
5. *Public Comment (6:15 p.m.)
6. Information Item – Irrigation Ditches (6:25 p.m.)
7. Information Item – Water Supply Update (6:40 p.m.)
8. Information Item – Boulder Creek TMDL Update (6:55 p.m.)
9. Information Item – Green Infrastructure Strategic Plan Update (7:15 p.m.)
10. Information Item – Rate Structure Implementation Update (7:35 p.m.)
11. Matters from the Board (7:55 p.m.)
12. Matters from Staff (8:05 p.m.)
13. Discussion of Future Schedule (8:10 p.m.)
14. Adjourn (8:15 p.m.)
* Public Comment Item
Agenda item times are approximate
Information:
• Please contact the WRAB Secretary email group at: WRABSecretary@bouldercolorado.gov
• Packets are available on-line at: http://www.bouldercolorado.gov – A to Z, Water Resources
Advisory Board (WRAB), Next Water Resources Advisory Board Meeting
WRAB Minutes
3/18/2019
Page No. 1
CITY OF BOULDER, COLORADO
BOARDS AND COMMISSIONS MEETING MINUTES
Name of Board / Commission: Water Resources Advisory Board
Date of Meeting: 18 March, 2019
Contact Information for Person Preparing Minutes: Erika Lowe, 303-441-4257
Board Members Present: Kate Ryan, Kirk Vincent, Ted Rose, Trisha Oeth
Board Members Absent: Lesley Smith
Staff Present: Jeff Arthur, Director of Public Works for Utilities
Douglas Sullivan, Principal Engineer Utilities
Ward Bauscher, Utilities Maintenance Manager
Steve Catanach, Director of Climate Initiatives
Ken Baird, Senior Financial Manager
Joe Taddeucci, Water Resources Manager
Katie Knapp, Engineering Project Manager-Flood Management/Greenways
Erika Lowe, Board Secretary
Agenda Item 1 – Call to Order [6:02 p.m.]
Agenda Item 2 – Approval of the 25 February 2019 Meeting Minutes [6:04 p.m.]
Approved
Moved by: Oeth Seconded by: Vincent
Vote: 3-0, Ted Rose abstained
Agenda Item 3 – Public Participation and Comment [6:06 p.m.]
Public Comment:
• Carl Norby: Five and a half years ago Boulder was jolted by devastating flood. City responded
by pursuing flood mitigation plans which included South Boulder Creek. Any project plans
have been put on hold due to lack of funds. Jeff Arthur accurately said the city has become
accustomed to creating plans with no dollars available, putting the plans on hold, then the
projects don’t get completed. So, no dollars are the big problem. Recently council purchased 2
farms for multi million dollars. Devoted to pursuing to underpasses going under 30th St. and
University. I go through them many times and see the students patiently waiting. I have never
seen a flood of people trying to get across. Recently they decided to up the ante for grants of
arts and cultures. I am all for Arts and Culture but not at the expense of floods, sewage in
homes, sickness/illness due to all the stuff you can acquire when it floods in your basement .
One of the final things asked: They wonder if 900 thousand dollars was enough for next year.
Examining a house purchase – need more middle income people to fill houses along creek to
get flooded? Requirement must earn at least 60% of median income in Boulder, not more than
120% of median income. WRAB previously spoke about priorities, it seems this is whole thing
is a major priority if you look back over the past five years. City Council meeting held in
January 2014 immediately after the flood, did not mention flooding at all.
• George Gerstle: Thanks for the opportunity to comment on the studies and analysis of the
Twomile Creek watershed and the options to mitigate the flooding in the watershed. Resides
adjacent to Twomile Creek between areas one and two between upper Twomile Creek at 4th
and Linden. I work for Boulder County and I want to be very clear I do not represent Boulder
County in my comments tonight. Our property was directly affected by 2013 flood, our home
was not impacted. In reviewing the analysis I do have a few observations and comments to
share. The first is the information presented today does not identify or summarize the benefits
of different alternatives. I found no representation of how many, or which homes, would
benefit, or be impacted from the different alternatives. For instance, I found no information on
how many, if any, homes on Kalmia and Juniper would be removed from the flood plain under
the various scenarios. Nor is any information presented on how many additional properties or
homes would be impacted through loss of vegetation, etc, by increasing the size of the Twomile
Creek channel. Secondly, there is no apparent analysis of the increase risk, or the increase in
number of affected properties from diverting the flows currently going down to Kalmia and
Juniper to the Twomile channel, especially in the less than 100-year channel alternative.
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Page No. 2
Without that analysis it appears impacts would merely be moved from Juniper residents to
Twomile Creek adjacent to Kalmia residents. Merely moving the damage from one place to
another. There is no apparent analysis in the increase size in culverts under Linden, Kalmia
and Juniper that would be necessary to pass the flows. That option would not be feasible
without elevating the roads, realigning the utilities, or taking adjacent properties and homes .
Fourth, the location of new crossing under Linden is proposed to be moved west from current
crossing, which is several hundred feet east of Wonderland Hill Drive. This change would
direct water above current channel and require creation of a new channel, easements of
property acquisitions, removal of large cottonwoo ds and likely require large structural walls, if
the angle of the culvert shown in analysis today is accurate. There is no analysis of how large
creek channel would have to be, or the impact to our house or property if creek channel is
widened. However, from the photos, it appears a new hundred-year flood plain boundary would
put our house back in the flood plain. This channel is a critical wildlife corridor and to remove
all the trees as indicated by the analysis, it would have a huge impact on the ecological health
of our system.
• John Gerstle: Liaison from Planning Board to WRAB. Planning board was interested to review
material being presented tonight. I want to encourage the WRAB to consider carefully the
benefits and costs associated with alternatives that will eventually be selected. These are things
Planning Board will be looking at carefully. Without explicit consideration of those factors, any
recommendations would be deficient.
Agenda Item 4 –Information Item - Energy & Climate Initiatives Update [6:15 p.m.]
Steve Catanach, Director of Climate Initiatives presented this item
WRAB Board Discussion Included:
• Question on how a city owned electric utility would interface with the three city owned water
utilities? Who pays for what?
• Comment on the City being the water utilities’ biggest customer and they do not pay for water.
Is the electric utility going to want free water or are they going to get free power?
• Question if the city owned electric utility would want to govern the hydroelectric facility?
• Question on when the bids for power were received and if they were for delivery in 2024
• Question based on bids and how reliable the pricing is the pricing.
• Question on what kind of counterparties is the City looking at with the bids
• Question if there are any concerns about delivery
• Question if the numbers shown are blended with the numbers purchased from City hydros or
purchasing from other DG facilities
• Curious if the electric utility would operate as an enterprise utility?
• Question if the billing process would separate electric utilities from water utilities
• Question if there has been any analysis or examination of other towns/cities that have their own
utilities. Is there an impact on rate setting when you have multiples utilities in one jurisdiction?
• Suggestion to show the numbers to the community. The numbers are c ompelling numbers, but
people need to know the numbers in order to see the benefit.
Public Comment:
• Gerhard Koepf: Hundreds of acres of Open Space and I wonder why do we not have a solar
plant there? Why don’t we generate our own energy with solar panels? Had we done this five
years ago, we would have tens of thousands of homes supplied by Boulder energy.
Agenda Item 5 – Information Item - Twomile Canyon Creek and [6:45 p.m.]
Upper Goose Creek Flood Information Study Update
EXECUTIVE SUMMARY:
This memorandum provides background information and an update on the Upper Goose and
Twomile Canyon Creek Flood Mitigation Study and associated coordination efforts with the
Alpine-Balsam Area Plan. Based on community feedback and technical screening several
alternatives were added and others removed from further consideration.
Next steps include additional alternatives assessment using the evaluation criteria developed for
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3/18/2019
Page No. 3
the Skunk Creek, Bluebell Canyon Creek and King’s Gulch Flood Mitigation Study; field
assessments of the existing creek channels; and consultation with potentially impacted property owners
and residents informing recommendations for draft mitigation plans. This memorandum
is intended to be informational and does not require WRAB action.
WRAB Board Discussion Included:
• Question of when the timeline for cost and detail of knowledge will be available to public.
Don’t want to leave the public with a false expectation that something will happen tomorrow.
• Comment on being glad the upstream detention idea was looked at and was not surprised how
costly it is
• Question about potential conveyance channel along eastern boundary foothills elementary and
what will be involved in that particular structural evaluation in the next months before getting
to selection of alternatives
• Question if there is any consideration of private property to the east of Foothills elementary and
if the City already knows whether it will be better suited for school property or private property
• Question if there could be more detail and clarification regarding North Boulder Park. It was
mentioned that City Council and Planning Board had recommended it be considered
functionality be maintained at the park. Would that mean keeping the same number of baseball
fields? How would functionality be maintained?
• Question on the priority on maintenance that is coming and if there is a way engineers can tell
how that will affect things and if it will change the way things are looked at and weighed.
• Comment on being given the larger context of all the things going on, there should be a high
priority for maintenance and aggressively pursuing that route since that is what most of the
public will see for a long time
• Comment on overestimating the risk of flooding at Alpine Balsam since it is an odd place for
flooding
• Make a request: Ask staff to construct a topographic map to illustrate Alpine Balsam flood risk.
Public Comment:
• Sarah Mayor – Live on Juniper behind Foothills School across Twomile Creek. I want to thank
staff for doing some maintenance on Twomile. It has a lot fewer down limbs now. I don’t
understand what running the channel down the street means? What does that look like? What
street? This is the only option that is left since everything else has been eliminated. Are there
multiple streets that have them? Virtually everyone on the south side of Juniper now has built
walls in front of house and raised their driveways, so more water stays in street instead of
going into their houses.
• Judy Nogg – Just a comment I want to make is what would make me feel the safest is more
maintenance on all ditches around since our condo is right up against the bike path. I am
hoping that while this overall study goes on, something can be done to communicate with
whoever does the maintenance to start doing this on a regular basis.
• John Gerstle: A comment that Planning Board has heard is that there is some concern deciding
what is happening on bottom end of the drainage before getting involved in top end so we
know where the water will actually be going. You mentioned that briefly with the Longs
Garden alternative, but with respect to Goose Creek the channel on the east side of Broadway
is constrained. So, there is some interest in learning how that will be dealt with east of
Broadway in addition to what happens west of Alpine Balsam site in North Boulder Park.
Agenda Item 6 – Information Item - South Boulder Creek Flood Mitigation [7:12 p.m.]
Update/ Stormwater & Flood Management Utility Funding
EXECUTIVE SUMMARY:
This memo is intended to provide WRAB an update on the South Boulder Creek Flood Mitigation
project. Since the development of the 2019-2024 Flood/Stormwater Capital Improvement Program
(CIP), additional planning, engineering, and discussion has taken plac e with WRAB, City Council and
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3/18/2019
Page No. 4
other stakeholders related to this project. This memo serves to highlight changes in the estimated project
cost and schedule, and to provide an overview regarding recent City Council updates.
WRAB Board Discussion Included:
• Question on what the most aggressive part of the chart would be
• Comment on the calendar being the justification for penciling in bonding for South Boulder
Creek in 2022, but the present problem is we have to fund next year. Question if this is what is
helping determine where in the long-term planning process this will show up.
• Estimates do not include OSO acquisition, but is it anticipated that the money will come out of
the water utilities bill?
• Question if CU submitted an annexation application and if it was confidential or open for
public review
• Question if project is not on time is there any cost to a delay
• Question if there are limitations on how long the City can build up funds for and how long can
they be held onto
Agenda Item 7 – Matters from the Board [7:36 p.m.]
• WRAB representative on the Greenways Committee is an open seat if anyone wants it, or else
Kirk Vincent will continue to occupy this seat
• Kirk Vincent will be attending Water Now conference in Austin next month
Agenda Item 8 – Matters from Staff [7:52 p.m.]
• Council is making Board appointments tomorrow night
• Design and Construction Standards Stakeholder meeting is March 25 at the Municipal
Services Center from 3-4 pm.
• WRAB members check calendars and see if any regularly scheduled meetings have
conflicts during summer
Agenda Item 9 – Discussion of Future Schedule [8:17 p.m.]
• April
- Open House Irrigation Ditches from 4-6 pm before next WRAB meeting, April 15 at the
Municipal Services Center building
- Water Supply update and refresher on drought plan
- Update on green infrastructure strategic plan
- Update Boulder Creek TMDL
- Potentially another update on rates and CIP
Agenda Item 10 - Adjournment [8: 21 p.m.]
Motion to adjourn by: Oeth Seconded by: Rose
Motion Passes 4:0
Date, Time, and Location of Next Meeting:
The next WRAB meeting will be Monday, April 15, 2019 at 6:00 p.m., at the City's Municipal
Services Center, 5050 Pearl St., Boulder, CO 80301
APPROVED BY: ATTESTED BY:
Board Chair: _________________________ Board Secretary: ____________________________
Date: _______________________________ Date:______________________________________
An audio recording of the full meeting for which these minutes are a summary is available on the Water
Resources Advisory Board web page.
https://bouldercolorado.gov/boards-commissions/water-resources-advisory-board-next-meeting-agenda-and-packet
C I T Y OF B O U L D E R
WATER RESOURCES ADVISORY BOARD
AGENDA ITEM
MEETING DATE: April 15, 2019
AGENDA TITLE: Information Item – Irrigation Ditches
PRESENTERS:
Jeff Arthur, Director of Public Works for Utilities
Joe Taddeucci, Water Resources Manager
Joanna Bloom, Water Resources Project Manager
Doug Dunn, Water Resources Specialist
Laila Parker, Source Water Administrator
EXECUTIVE SUMMARY
Irrigation ditches are a component of many projects, master plans and other community utilities
issues on which WRAB has an advisory role. The purpose of this item is to summarize Utilities’
relationship to irrigation ditches and provide WRAB members with an opportunity to ask
questions or request additional information. Additionally, the community open house held before
the April WRAB meeting is intended to provide community members, ditch representatives and
staff an opportunity to interact and share information.
BACKGROUND
Boulder city limits contain seventeen private irrigation ditches that deliver water from Boulder
Creek and South Boulder Creek to shareholders such as homes, farms, businesses and city
departments. The attached July 2018 City Council Information Packet Item summarizes ditch
ownership and management structures, operations and maintenance practices and property rights,
city roles relevant to ditches and an analysis of benefits and challenges related to ditches.
ANALYSIS
In some cases, irrigation ditches can be a prominent consideration in matters directly in WRAB’s
purview such as capital improvement projects or policy considerations. For example, the current
South Boulder Creek flood mitigation plans will likely require realignment of a portion of the Dry
Creek No. 2 ditch and will require consideration of how flood waters will interact with
downstream ditches. Capital Improvement Project upgrades at the Water Resource Recovery
Facility are of interest to downstream ditch companies with concerns about water quality in
Boulder Creek. Stormwater policy and funding proposals brought before WRAB, such as the
updated Design and Construction Standards and the annual stormwater utility capital budget, are
relevant to ditches which carry the city’s stormwater runoff.
While WRAB’s role is less direct when it comes to Utilities operations, staff time and costs
required to address ditch-related issues provide relevant context for matters under WRAB’s
purview, such as capital improvement budgets. For reference, city costs related to ditches vary
annually and were roughly one million dollars in 2017. Besides predictable operational costs for
04/15/2019 - WRAB Agenda 6 - Irrigation Ditches
Page 1
annual ditch company shareholder assessments and stormwater carriage fees, these costs may be
associated with the following:
•City capital improvement projects in both Public Works and other departments frequently
cross a ditch. Project managers may have expenses related to ditch crossings, assuming
maintenance or building infrastructure to accommodate both ditch and city purposes. For
example, the Parks and Recreation Department’s redevelopment of the Scott Carpenter Pool
involves realignment of the Smith-Goss and McCarty ditches, which required significant
Utilities staff time for negotiation among stakeholders, including ditch companies.
•Maintenance staff need to be cognizant of and responsive to ditch operational schedules and
expectations. For example, when ditches turn on in the spring, maintenance staff may be
required to perform significant debris clearing in portions of ditches where the city has
assumed ongoing maintenance responsibility due to previous alterations by city capital
improvement projects.
At times, conflict related to irrigation ditch matters can generate significant community, City
Council and media interest, and management of such issues often involves significant Utilities
staff time. For example, the attached City Council Information Packet Item came about partially
in response to community concerns about increased mosquito populations related to factors
including standing water in ditches. Similarly, in recent years various ditch companies have
determined select tree removals were necessary to restore and maintain ditch capacity to deliver
water to shareholders. Such tree removal plans at times result in neighboring community
members calls for staff and council intervention to allow the trees to remain. Residents may also
express concerns related to ditch water seeping into basements and across yards and pavement.
In many cases, such as the examples described above, community members have mentioned the
apparent lack of information available to the public regarding how ditches work and are managed.
In response to such feedback, city staff have increased public awareness efforts, including
development of an irrigation ditch website, which includes an irrigation ditch brochure and FAQ
document, a map of irrigation ditches and contact information for city staff. Additionally, staff
have established an irrigation ditch station at citywide public outreach events. Staff have also
considered community events specifically for irrigation ditches. This information item and the
associated open house are intended as a test case for such specific irrigation ditch related
outreach. While no action is required of WRAB, staff would like WRAB and community
feedback on the open house concept to inform development of future similar events.
NEXT STEPS
Staff are available to address WRAB questions or requests for additional information regarding
irrigation ditches as desired. Staff will continue to develop education and outreach materials and
will evaluate future community engagement opportunities related to irrigation ditches.
ATTACHMENTS
A – July 12, 2018 Information Packet Memorandum to Council: “Irrigation Ditch Overview”
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INFORMATION PACKET
MEMORANDUM
To: Mayor and Members of Council
From: Jane S. Brautigam, City Manager
Maureen Rait, Executive Director of Public Works
Dan Burke, Interim Director of Open Space and Mountain Parks
Jeff Arthur, Director of Public Works for Utilities
John Potter, Resource and Stewardship Manager, Open Space and Mountain Parks
Joe Taddeucci, Water Resources Manager, Utilities
Ward Bauscher, Utilities Maintenance Manager
Date: July 12, 2018
Subject: Irrigation Ditch Overview
EXECUTIVE SUMMARY
Boulder city limits contain a number of private irrigation ditches that deliver water diverted from
Boulder Creek and South Boulder Creek to shareholders, such as homes, farms, businesses,
industries and city departments, including Public Works, Open Space and Mountain Parks and
Parks and Recreation. Irrigation ditches provide numerous benefits to both shareholders and the
community at large but can also present challenges that at times result in community requests for
city assistance. This memo provides an overview of irrigation ditches in Boulder, including a
summary of their ownership and management structure, operation and maintenance practices and
property rights. It also includes an analysis of benefits and typical issues related to ditches, as
well as a summary of city roles relative to ditches, which can involve city ownership interest as a
ditch company shareholder and city staff holding ditch company board positions.
FISCAL IMPACT
City costs related to ditches consist of annual ditch company shareholder assessments, variable
costs associated with city maintenance obligations and time allocated to ditches by certain staff
positions. City costs can be a million dollars or more per year out of city departmental operating
budgets. Depending on the maintenance and other issues that arise in any given year, costs can
vary by several hundred thousand dollars from year to year. In 2017, city ditch related costs
were roughly a million dollars.
Attachment A
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COMMUNITY SUSTAINABILITY ASSESSMENTS AND IMPACTS
x Economic: Irrigation ditch water is essential to local agriculture and the local economy.
However, ditch companies’ financial structure and duty to maintain low operating costs for
shareholders can result in restoration and maintenance expenses for private property owners.
x Environmental: Ditches create habitat for vegetation and wildlife and provide an alternative
to treated drinking water for outdoor irrigation. However, ditch maintenance activities can
cause significant ecological disturbances, which on city open space can require mitigation
work by city staff.
x Social: Irrigation ditches benefit agriculture and can create a sense of community among
shareholders and neighbors. Conversely, the differing interests of ditch companies and
property owners can result in significant conflict.
BACKGROUND
Irrigation ditches were a fundamental feature of Boulder’s settlement in the late 1800s, and their
physical locations and form as earthen channels remains largely unchanged for those ditches still
in existence today. In most cases, irrigation ditches predate other forms of city development,
including most streets, buildings and houses.
Irrigation ditches are manmade channels that divert water from natural streams for delivery to
shareholders who are often located many miles away. Ditch shareholders use the water for
various purposes mostly related to agricultural irrigation, and ditches typically operate seasonally
from April through October. The amount of water flowing in a ditch is governed by shareholder
need and whether there is enough water in the stream to accommodate the ditch company’s water
rights. Ditch flows can be dramatically influenced by water intercepted during storms, and in
some cases the city has stormwater carriage agreements with certain ditch companies.
Ditch companies rarely own the land underlying the ditch. Instead, they typically have
prescriptive easements to access, operate and maintain the ditch. Prescriptive easements are not
granted by the underlying property owner and are not recorded in property records, and even
though they are vaguely defined by law as “whatever is reasonable and necessary in the
operation and maintenance of the ditch,” they constitute vested, legally-recognized property
rights. City regulatory authority over ditches is limited, as irrigation ditches are primarily
governed by state property and water rights laws.
Ditch companies are typically privately owned and operated and are not-for-profit corporations
whose mission is delivering water to shareholders. Ditch companies are made up of and funded
by their shareholders and are governed by an elected, volunteer board of directors. Board
members are responsible for managing the ditch, including overseeing operations and use of
company funds on behalf of shareholder interests. Day-to-day ditch operations are managed by a
person called a “ditch superintendent” or “ditch rider.”
The City of Boulder has an ownership interest varying from 2 to 100 percent of shares in more
than 30 different irrigation ditch companies. In cases where the city has a large share, city staff
sometimes fulfill ditch company board positions. Public Works staff currently hold board
positions for three different ditch companies and Open Space and Mountain Parks staff hold
board positions for eleven companies as detailed in Attachment 1.
Attachment A
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Page 4
City staff are also involved in ditch matters related to certain city maintenance responsibilities,
development review concerning ditch easements, annexations for properties with ditch shares
and assistance resolving ditch-related conflicts between property owners and ditch companies.
For more information on the various city ditch-related roles, including how staff manage
potential conflicts of interest when serving as ditch company board members, please refer to
Attachment 2.
ANALYSIS
Irrigation ditches are important to the history and culture of Boulder and have supported local
agriculture for over 150 years, including irrigation of city open space and parks as well as
residential and commercial properties. Ditches provide a network of green, vegetated corridors
throughout the city and can provide a sense of community among shareholders and neighbors as
well as habitats for wildlife. Many property owners value ditches for their aesthetic benefits and
peaceful sounds, and the water rights associated with ditches are a vital component of city water
supply.
While irrigation ditches provide many community benefits and essential shareholder functions,
living next to or near a ditch also involves constraints and impacts. Home and business owners
whose property is subject to a ditch easement are limited in vegetation and development options
within the easement. Ditch maintenance, including vegetation removal, dredging, bank
rebuilding and other cleanup activities, is often a source of conflict between property owners and
ditch companies. Ditch companies also selectively remove large trees to maintain access and
flow capacity, and the loss of trees is most often unwelcomed by property owners and the
community.
Other common ditch issues include standing water and ditch seepage. Standing water can be a
source of unpleasant odors and mosquito breeding when ditches are not running and can be
particularly prevalent at the boundaries between urban development and agricultural and open
space land. Seepage can cause basement infiltration, saturated ground in yards and trails and wet
areas on streets and sidewalks.
The most common issues of concern for adjacent property owners relate to ditch operational and
maintenance practices that are not subject to city regulatory authority but are instead protected by
state property and water rights laws. Ditch companies strive to maintain low operating costs for
shareholders, among which are agricultural operators with often limited financial resources.
Between the goal of controlling costs, the legal protection afforded to ditch companies and the
fact that most property development occurred after ditches were well established, the onus
typically is on property owners to address common issues such as basement seepage and
restoration following ditch maintenance. When conflicts arise, public perception tends to favor
property owners and community interests, while the legal framework tends to support ditch
companies. In most cases, all parties have valid but competing interests.
NEXT STEPS
Resolution of ditch-related conflicts requires cooperation and compromise as well as creative
solutions that strike an appropriate balance of the interests involved. Current staff work plan
objectives include expanding community education, continued work on ditch signage, outreach
and volunteer opportunities and continuing to work on solutions for common ditch-related
issues. New and existing property owners can learn more about living next to a ditch by referring
to Attachments 3, 4 and 5 of this memo, which include an irrigation ditch brochure, frequently
asked questions (FAQ) and an irrigation ditch map. Both the brochure and the FAQ provide links
Attachment A
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Page 5
for additional resources and contact information that community members can use to learn
additional information or request assistance with a specific ditch-related matter.
ATTACHMENTS
Attachment $– Irrigation Ditch Table with City of Boulder Interests
Attachment % – Supplemental Information
Attachment &- Irrigation Ditch Brochure
Attachment '-Irrigation Ditch Frequently Asked Questions
Attachment ( – Irrigation Ditch Map
Attachment A
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CITY OF BOULDER OWNERSHIP INTEREST IN IRRIGATION DITCHESIRRIGATION DITCH NAME** Runs within Boulder city limitsDITCH COMPANY BOARD -OF-DIRECTOR POSITIONSCITY OF BOULDER SHARE OWNERSHIPCITY OF BOULDER OWNERSHIPSOURCE1 Agitator DitchUtilities StaffOSMP25%South Boulder Creek2 Anderson Ditch**Utilities StaffUtilities;Transportation62%Boulder Creek 3 Anderson Extension**0%South Boulder Creek4 Andrew's FarewellOSMP8%South Boulder Creek5 Arnold HarropOSMP100%Boulder Creek (seepage)6 Boulder & White Rock Ditch**Utilities; OSMP 4%Boulder Creek 7 Boulder Left Hand Ditch** OSMP StaffOSMP2%Boulder Creek 8 Butte Mill Ditch**OSMP StaffOSMP49%Boulder & South Boulder Creeks9 Cottonwood #2 DitchOSMP38%South Boulder Creek10 Davidson DitchOSMP StaffOSMP17%South Boulder Creek11 Davidson Highline Ditch OSMP Staff OSMP 1% South Boulder Creek12 Dry Creek Davidson Ditch OSMP StaffOSMP41%South Boulder Creek13 Dry Creek No. 2 Ditch** OSMP StaffParks; OSMP 35%South Boulder Creek14 East Boulder DitchOSMP2%South Boulder Creek15 Eggleston Ditch 1OSMP100%Coal Creek16 Eggleston Ditch 4OSMP100%Coal Creek17 Enterprise DitchOSMP11%South Boulder Creek18 Farmers Ditch**Utilities StaffUtilities; OSMP 74%Boulder Creek 19 Farmers Reservoir & Irrigation Co.OSMP 2% South Boulder Creek20 Green Ditch**OSMP StaffOSMP80%Boulder Creek 21 Howard Ditch**OSMP StaffParks; OSMP 80%South Boulder CreekAttachment A - Irrigation Ditch Table with City of Boulder InterestsAttachment A
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CITY OF BOULDER OWNERSHIP INTEREST IN IRRIGATION DITCHESIRRIGATION DITCH NAME** Runs within Boulder city limitsDITCH COMPANY BOARD -OF-DIRECTOR POSITIONSCITY OF BOULDER SHARE OWNERSHIPCITY OF BOULDER OWNERSHIPSOURCE22 Jones Donnelly Ditch** OSMP Staff OSMP 28% South Boulder Creek23 Left Hand Ditch/North Tollgate OSMP Staff OSMP; Utilities 15% Left Hand Creek24 Leyner Cottonwood DitchOSMP7%South Boulder Creek25 LF Spicer DitchOSMP100%South Boulder Creek (seepage)26 Marshallville DitchOSMP38%South Boulder Creek27 McCarty Ditch**0%Boulder Creek 28 McGinn DitchOSMP38%South Boulder Creek29 North Boulder Farmers Ditch**Utilities; OSMP;Parks25%Boulder Creek 30 Orcine DitchOSMP100%Boulder Creek (seepage)31 Shearer Ditch**OSMP100%South Boulder Creek32 Silver Lake Ditch**Parks; OSMP;Utilities7%Boulder Creek33 Smith & Goss Ditch**Utilities2%Boulder Creek 34 South Boulder Bear Creek Ditch OSMP Staff OSMP 9% South Boulder Creek35 South Boulder Canon Ditch**OSMP 9% South Boulder Creek36 Swede DitchOSMP0.05%St. Vrain Creek37 Wellman Ditch**0%Boulder Creek 38 William C. Hake DitchOSMP44%Coal CreekAttachment A - Irrigation Ditch Table with City of Boulder InterestsAttachment A
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Attachment % – Supplemental Information
Below is supplemental information about topics covered in the memo.
City Staff Considerations Relative to Ditches - When city staff hold ditch company board
positions, which typically is a formal requirement noted in their city job descriptions, they have a
duty to represent all ditch shareholder interests and cannot prioritize city interests to the
detriment of other shareholders.
If a community request for city assistance involves a ditch company for which the city holds
board positions, city staffing assignments are made to minimize any conflicts of interest. The
staff members who hold the ditch board positions will recuse themselves from voting on such
issues on behalf of the ditch company as may be appropriate, and property owner and city
interests will often be represented by city staff who do not hold ditch board positions.
Ditches Relative to City Infrastructure - Even though the city may have shares in a ditch and
hold board positions, the ditch is still a private facility and is not city infrastructure like a street
or drinking water distribution system pipe. Accordingly, the city does not have control over day-
to-day ditch operations and maintenance.
Ditches and City Stormwater - Portions of the city’s stormwater system were designed in an
earlier time when it was common to locate municipal stormwater outfalls in irrigation ditches.
The city has formal agreements with certain ditch companies to reserve capacity in the ditch for
city stormwater, including provision of city funds for maintaining ditch capacity.
City Maintenance of Ditches – When city facilities such as a multi-use paths, parks or roads are
constructed within ditch easements, the city will often enter a written agreement with the
affected ditch company whereby the city takes on certain maintenance responsibilities. There are
many such agreements for city ditch maintenance responsibility for specific ditch sections
throughout the city, however, ditch companies self-perform most maintenance. City staff also
work closely with the ditch companies to minimize disturbances and mitigate impacts of ditch
maintenance work on city open space.
City Development Review Process and Ditches - If a business or residence proposes
development within a ditch easement, city process requires the applicant to obtain ditch company
approval, which typically comes in the form of a formal agreement with the ditch company. City
staff frequently provide support for this agreement process.
City Annexation Process and Ditches - When a property undergoes an annexation or
development process, city staff advise property owners of their options related to ditch shares
under city code and sometimes separate ditch agreement
1 provisions. The code or agreement
provisions allow property owners to retain their water rights or ditch shares upon request for City
water service but grant the city preferential options for future acquisition of such rights and
shares at the time such water is sold off the property. During the annexation process, the City and
property owner may negotiate for the conveyance of ditch shares or other water rights associated
with the property to the City as part of the annexation.
City Water Supply and Ditches Thirty percent of the city’s annual drinking water supply on
average is attributable to irrigation ditch shares acquired by the city over time. In most cases, the
city’s ditch shares have been changed through the water court process to allow for an alternative
point of diversion such as the city’s water supply reservoirs.
1 Section 11-1-19 of the Boulder Revised Code addresses water and ditch rights, including reference to separate city
and ditch company agreements that control when in effect.
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$WWDFKPHQW&,UULJDWLRQ'LWFK%URFKXUHAttachment A
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$WWDFKPHQW&,UULJDWLRQ'LWFK%URFKXUHAttachment A04/15/2019 - WRAB Agenda 6 - Irrigation Ditches Page 11
Irrigation Ditch
Frequently Asked Questions
City of Boulder - 2016
Attachment A
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Table of Contents
1) General Page 3
2) Ditch Companies Page 6
3) Ditch Maintenance Page 8
4) For Homeowners Page 9
5) For Developers Page 10
6) Ditch Map Page 12
7) More Information Page 13
Attachment A
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1) General
What do irrigation ditches do?
The original purpose of most irrigation ditches was to deliver water to farmland under the ditch. Ditches also
delivered drinking water to the homes of early Boulder settlers. Local agriculture and development in the late
1800’s in the Boulder area would not have been possible without irrigation ditches.
Ditches as structures have not changed much over time and
still serve agriculture and homes, but also serve parks, cities,
and businesses. Although the purpose of ditches is to deliver
water in a safe and efficient manner, irrigation ditches are
often also valued for their incidental aesthetic and
environmental benefits.
Did you know? Approximately 53 miles of irrigation
ditch still run through the City of Boulder today. Seven miles
of ditches have been buried in underground pipelines as
development has progressed.
How do irrigation ditches benefit the local community?
Irrigation ditch water is essential to sustaining local agriculture. Many of the producers that depend on this
water sell their goods to local restaurants and businesses and at the farmer’s market. Ditches also provide an
economical and environmentally friendly alternative to using treated drinking water to irrigate parks, schools,
and open spaces. Irrigation ditches also sometimes carry municipal water attributable to shares owned by
the city that is eventually treated and delivered to customers.
What is the difference between an irrigation ditch and a stream?
Streams are natural water bodies. Irrigation ditches are manmade channels that take water from natural
streams for delivery to homes, farms, businesses, industries and other uses. The water flowing in streams is
generally naturally occurring. The flow of water in a ditch is controlled by people who work for a ditch
company. Most ditches deliver water from April to October, but some ditches continue to run over the
winter. The amount, timing, and use of the water diverted into a ditch are based upon one or multiple water
rights.
Why does a ditch flow only some of the time?
Irrigation ditches typically run from April through October. An irrigation ditch will only run if shareholders
need water and if there is enough water in the creek under the ditch’s water rights. Some ditches run water
in the winter to fill reservoirs. During times of fluctuating demand and supply, irrigation ditch flows can vary
greatly, with some ditches turning on or off with little notice. Some ditches also intercept surface and
stormwater drainage, so flows can fluctuate during storm events.
BLACK CAT FARM IS ONE EXAMPLE OF LOCAL
AGRICULTURE IRRIGATED BY DITCHES
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Did you know? The Smith & Goss Ditch was originally constructed in 1859 only a year after the first
miners settled in the area. Water delivered through the Smith & Goss is still used to irrigate portions of
central Boulder that now include Boulder High School and the University of Colorado.
What is the difference between an irrigation ditch and a lateral?
Most ditches include the main ditch and a number of
branches called laterals. The main ditch diverts
water from a creek and can be fairly large and
visible. A lateral branches off of the main ditch and
carries less water for delivery to specific properties.
Shareholders who receive water through a lateral
are typically responsible for the lateral’s
management, operation, and maintenance. Laterals
may also be privately owned and operated, and not
formally affiliated with the ditch company.
Did you know? 98 ditch companies were
diverting water from Boulder Creek by 1882.
THE HOWELL DITCH (LEFT) RUNS NEXT TO BOULDER CREEK
(RIGHT). DITCHES TYPICALLY HAVE FLATTER SLOPES AND
SLOWER FLOWS THAN NATURAL DRAINAGES.
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What is a prescriptive easement and why can’t I find any related documentation?
Ditch Companies rarely own the land underlying the ditch or a recorded easement. Instead, they typically
have prescriptive easements to access, operate and maintain the ditch. Prescriptive easements are not
purchased, negotiated or granted by the underlying property owner, but are established by visible and
continuous use that dates back to the original construction of the ditch and may evolve over time based on
operation and maintenance practices. Even though these easements may seem informal, they constitute
vested property rights that are protected under state law. Because prescriptive easements are rarely
quantified or documented, home and business owners
may be surprised to discover that their property is
subject to a ditch easement that predated their
ownership, and in many cases predated the
development of their property.
How wide is the ditch easement?
The width of a prescriptive easement can vary and is
defined as whatever is “reasonable and necessary” to
maintain, access, and operate the ditch. Ditch
maintenance can include access by heavy machinery,
removal of sediment and vegetation (including trees),
and the placement of material on the ditch banks.
Did you know? The original property owners
benefited from, and sometimes were, the original
founders of the ditch; therefore, they often encouraged
the ditch to be constructed across or adjacent to their
land.
What are the recreation opportunities associated with
ditches?
Ditch companies have liability concerns and discourage
public access and recreation within the ditch easement.
Ditches have steep banks, enclosed sections, and
unpredictable flows, which can be dangerous.
IRRIGATION DITCH DIVERSION AT BROADWAY IN CENTRAL
PARK THROUGH THE YEARS. SOURCE: CARNEGIE BRANCH
LIBRARY FOR LOCAL HISTORY/BOULDER HISTORICAL
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2) Ditch Companies
What is a ditch company?
In general, ditch companies are private, not-for-profit companies made up of shareholders. Shareholders
receive water from the ditch company and are required to pay a fee (assessment) to support ditch operations
and maintenance. Both the assessments paid and amount of water received are in proportion to a
shareholder’s ownership (shares) in the company. Shareholders can be individuals or institutions, such as a
school district, or a government agency, such as a city or county.
How does a ditch company operate?
Most ditch companies are operated by a voluntary board of
directors. Board members are elected at annual
shareholders’ meetings and typically are shareholders
themselves. In some cases, board members are also city
employees who serve on the board as a representative of
the city’s share ownership. In Boulder, city staff who serve
on ditch boards most often work in either the Public Works
or Open Space and Mountain Parks Departments. Board
members have a duty to operate the ditch company and
make decisions on behalf of the interests of all shareholders
in the ditch.
Day to day operations of the ditch are controlled by a
person called a ditch superintendent or “ditch rider”. The
ditch rider generally maintains the ditch to safely carry
water and manages water deliveries to shareholders.
Deliveries are made depending on shareholder demand,
water availability in the creek, and the ditch’s respective
water rights are in priority.
Did you know? In 1953 Farmers Ditch constructed the largest siphon in Boulder, eliminating 3,300 ft. of
open ditch by burying it under North Boulder Park.
What are the primary responsibilities of a ditch company?
A ditch company is primarily responsible for delivering water to its shareholders. Ditch companies are
required by state statute to maintain the ditch in good repair (i.e. to minimize overtopping and to efficiently
deliver water).
A PAGE FROM THE DITCH RIDER’S BOOK ON SMITH &
GOSS DITCH (1943). DIVERSION RECORDS,
IRRIGATED ACRES AND TYPE OF CROPS GROWN ARE
ALL RECORDED.
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What does a ditch company own?
Ditch companies hold the right to divert water for the beneficial use by their shareholders, and the physical
structures needed to deliver it to shareholders. Ditch companies also have easement rights to access,
operate, and maintain the ditch. Although ditch companies often do not own the land underlying the ditch,
ditch easements subject any surrounding property to certain limitations for building and planting. In general,
the underlying property owner cannot alter the property within the easement in a way that interferes with
the operation and maintenance of the ditch.
When do I need an agreement with a ditch company?
Building, planting, or other modification within the ditch easement typically requires ditch company approval
in the form of a written agreement. The approval process can take up to several months. Typically ditch
companies require property owners or project proponents to reimburse the ditch company for its legal and
engineering review costs associated with the
project. The agreement protects both the ditch
company’s rights as well as the project
improvements.
What is Boulder’s relationship to ditch
companies?
Boulder works closely with irrigation ditch
companies as a neighboring water user who
shares common water sources, such as Boulder
Creek. The City of Boulder is also a shareholder in
more than 30 different ditch companies. Roughly
30 percent of the city’s drinking water supply
originates from irrigation ditch water rights.
These rights allow Boulder to divert water into
the city’s municipal water supply system for
treatment and delivery to customers. The city also
uses ditch water to support the preservation of
local agriculture on its open space land and
through its agricultural leasing program, and to
minimize the use of treated water at city facilities,
such as city parks. In some cases, Boulder has
agreements with the ditch company to carry
storm water when excess ditch capacity is
available.
CONSTRUCTION OF THE FARMERS DITCH SIPHON UNDER NORTH
BOULDER PARK (1953). SOURCE: CARNEGIE BRANCH LIBRARY FOR
LOCAL HISTORY/BOULDER HISTORICAL SOCIETY COLLECTION.
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3) Ditch Maintenance
What can be expected during ditch maintenance?
Ditch Companies perform routine maintenance as necessary to ensure unobstructed flow of water. Routine
maintenance may include brush and tree removal, dredging, bank rebuilding and other cleanup activities.
Frequently ditch companies use dredged material to reinforce the ditch bank; therefore, it is best to work
with the respective ditch company before moving any dirt within the easement. Homeowners may choose to
dispose of other materials left in the easement following maintenance, as ditch companies generally do not
haul vegetation and trash away.
Ditch companies typically operate on a limited budget and may perform more extensive maintenance work
on a several year schedule; such work may include the removal of large trees and more extensive dredging
and sediment removal.
Trash and Debris
While some vegetation naturally accumulates in the ditch,
other debris like grass clippings, yard waste, plastic bags, and
litter can obstruct ditch flow as well as pollute downstream
waterways and lakes. Trash or yard waste should not be
deposited in ditches.
Did you know? There are 17 irrigation ditches that flow
within the city limits and more than 40 irrigation ditches
throughout the greater Boulder Valley.
Trees
Trees thrive along waterways and are valued by the community for their aesthetic and environmental
benefits. Unfortunately, trees and roots can compromise the ditch bank, reduce flow capacity, block
maintenance access, and create snags that can collect debris and result in flooding. Ditch companies
selectively remove trees from within the easement to support ditch operations and reduce flooding risk.
TRASH RACKS COLLECT DEBRIS FLOATING DOWN THE
DITCH. THEY NEED TO BE CLEANED REGULARLY BY THE
DITCH COMPANY
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4) For Homeowners
What do I do if the ditch is seeping into my house?
Seepage from irrigation ditches is a historic and common occurrence. The amount of seepage can change not
only as the ditch runs, but also with seasons and weather patterns. It is generally up to the land owner to
address seepage on their property. An expert, such as an engineer or plumber, can evaluate the situation and
examine possible mitigation options such as a sump pump or drainage system. Additionally, because plant
and tree roots can exacerbate seepage, it is best to avoid planting near the ditch bank.
How are irrigation ditches addressed during real estate transactions?
Professionals working outside of the water resource field may not be aware of water rights, ditch operations,
ditch easements, and the relevant state law. Because prescriptive easements are rarely documented, they
may not come up in a title search. City of Boulder Water Resources staff or individual ditch companies can
provide more information about ditches running through or
adjacent to prospective properties and should be consulted in real
estate transactions.
How can I start using the water from the ditch on my property?
Even though a property may have a ditch running through it,
landowners may only use the water if they own shares in the ditch
company or lease water for use on lands under the ditch, or have
some other contractual right to the delivery of water with the ditch
company. Shares can be purchased from the previous property
owner, from other shareholders, or directly from the ditch company
if and when available. Once the shares have been purchased, the
landowner should work closely with ditch company staff to
facilitate the delivery of water. SEDIMENT AND VEGETATION REMOVAL
IMPROVES THE EFFICIENCY OF THE FLOW OF
WATER AND CAN ADDRESS ISSUES SUCH AS
SEEPAGE.
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5) For Developers
What authorization is needed to work or develop in the ditch easement?
Work within the ditch easement, whether permanent or temporary, will require an agreement with the ditch
company. Ditch Company approval protects both landowner and ditch company interests. For example,
without an agreement, the Ditch Company may remove features within the easement during operation and
maintenance activities. Because prescriptive easements for the ditch are difficult to quantify and define, it is
recommended that a developer contact the respective ditch company if work will occur within 50 feet of
either side of a ditch.
A ditch company discharge agreement and/or city
dewatering and/or stormwater permit may also
be required if the surrounding drainage is
modified or if a sump pump will discharge into the
ditch. This includes temporary dewatering
activities during construction. The city’s Planning
& Development Services Department can provide
guidance on other local, state, and federal
regulations.
What is the process for getting an agreement with the ditch company?
The process starts with informing the ditch company of design plans. This is best done as early on as possible,
as they may provide informal input that can save time and money later. The ditch company will then refer
the plans to an engineer and attorney of their choice for review. Once the scope of work and the details of
the agreement are approved by both parties, a written agreement is typically drafted by the ditch company
attorney. Both parties must sign the agreement before work can begin.
How long will it take to get an agreement with the ditch company?
Typically, the agreement process can take two to six
months or longer. The time required can vary
significantly depending on project extent, time of year,
and the resources available to the ditch company.
Each ditch company likely has a different approach to
handling agreements. For example, some ditch
companies may have to wait until the annual meeting
to make decisions on larger projects. To streamline
the process, include the ditch company as early as
possible and throughout the project.
FARMERS DITCH WAS USED TO HISTORICALLY IRRIGATE A FARM
THROUGH THIS BOULDER NEIGHBORHOOD.
Development or Permitting Questions?
City of Boulder Planning and
Development Services
Email: plandevelop@bouldercolorado.gov
Phone: 303-441-1880
Fax: 303-441-4241
www.bouldercolorado.gov/plan-develop
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What costs are associated with development within the ditch easement?
Ditch companies charge fees to recover costs associated with the project. Costs are related to the review
performed by the ditch company’s attorneys and engineers as well as administrative fees and are generally
dependent on project complexity. Ditch companies may also charge a “crossing fee” as partial consideration
for granting permission to modify their ditch easement.
Attachment A
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6) Ditch Map
Attachment A
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7) More Information
For more information related to irrigation ditches in and around the City of Boulder, please contact City of
Boulder Water Resources staff at 303-441-3266 or visit our website at
www.bouldercolorado.gov/water/ditches.
The following resources also provide additional information:
x City of Boulder Irrigation Ditches: www.bouldercolorado.gov/water/ditches
x Boulder Valley Comprehensive Plan: www.bouldercolorado.gov/bvcp
x City of Boulder Source Water Master Plan:
www.bouldercolorado.gov/water/water-utility-master-plan
x Boulder County Ditch Map: www.bouldercounty.org/doc/transportation/ditchmap.pdf
x CSU Extension Ditch Fact Sheet:
www.extension.colostate.edu/topic-areas/natural-resources/irrigation-ditches-and-their-operation-
6-701
x Colorado Division of Water Resources, Division No. 1:
www.water.state.co.us/DivisionsOffices/Div1SPlatteRiverBasin/Pages/Div1SPlatteRB.aspx
x Colorado Decision Support System (CWCB and DWR water management system), available at:
www.cdss.state.co.us/pages/CDSSHome.aspx
x Colorado Water Law for Non-Lawyers, by P. Andrew Jones and Tom Czech
x Ditch and Reservoir Company Alliance: www.darca.org
x Colorado Foundation for Water Education: www.yourwatercolorado.org
Attachment A
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Attachment A
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C I T Y OF B O U L D E R
WATER RESOURCES ADVISORY BOARD
AGENDA ITEM
MEETING DATE: April 15, 2019
AGENDA TITLE: Information Item – Drought Response Overview and Water Supply
Update
PRESENTERS:
Jeff Arthur, Director of Public Works for Utilities
Joe Taddeucci, Water Resources Manager
Kim Hutton, Water Resources Engineer
Eric Johnson, Water Resources Facilities Manager
EXECUTIVE SUMMARY:
This memo provides an update on 2019 water supply conditions and the city’s drought stage
determination procedures as set forth in the Drought Plan (Attachment A).
BACKGROUND:
The Drought Plan consists of two separate volumes and is intended to provide guidance for
recognizing and responding to droughts that will affect water supply availability. Volume I
categorizes drought alert levels according to severity and also includes actions that might be taken
to respond to each drought alert level. Volume II contains detailed technical supporting
information.
During development of the Drought Plan, the city established a formula called the “storage
index”. The storage index was derived from statistical analysis and modeling of Boulder’s water
system using historical hydrology. The storage index is basically a ratio of key storage
parameters divided by projected demand. Staff applies the formula each year in early May when
key water supply information becomes known. The drought alert levels corresponding to various
storage index values are shown in Table 1.
The Drought Plan identifies water use reduction goals and response options for each drought
stage. The storage index calculation is one component of staff’s evaluation of water supply
conditions and is reviewed in conjunction with other appropriate data and operating experience.
While early May is a decision point in Boulder’s drought response analysis, staff continuously
monitors trends in snowpack, precipitation, runoff, reservoir filling and water rights
administration throughout the year.
04.15.2019 - WRAB Agenda 7 - Water Supply Update
Page 1
Table 1: Suggested drought response triggers for May 1
(City of Boulder Drought Plan, Volume 1)
Projected
Storage Index (1) Drought Alert Stage
Greater than 0.85 None
Between 0.85 and 0.7 I
Between 0.7 and 0.55 II
Between 0.55 and 0.4 III
Less than 0.4 IV
(1)Projected storage index = (projected usable Boulder mountain storage + 40% of
Boulder’s portion of projected CBT storage) / Boulder’s unrestrained water demand in non-drought years.
ANALYSIS:
The city’s water supply system includes both native basin (North and Middle Boulder Creeks)
and Colorado-Big Thompson (CBT) water sources, which lie within the larger South Platte and
Colorado River basins respectively (Attachment B). As of April 4, 2019, the city’s water supply
conditions were as follows:
• Snowpack is 120 – 130% of average for this time of year in the South Platte and Colorado
River basins. Snow water equivalent measurements are just over 100% of average for the
snow course and SNOTEL sites in the Boulder Creek basin. Boulder Creek and statewide
graphs and maps relevant to Boulder’s water supply conditions are shown in Attachment C.
• Mountain reservoir storage levels in the North and Middle Boulder Creek basins are slightly
below average but within the normal operating range for this time of year and staff anticipates
all reservoirs will fill during spring runoff. Attachment D shows Boulder’s mountain reservoir
storage levels for the past several years.
• Initial indications from the Northern Colorado Water Conservancy District (Northern Water)
are that the Colorado-Big Thompson (CBT) 2019 allocation will be 60-70%1. A 60%
allocation represents 12,600 acre-feet of water available to the city. A 70% allocation
represents 14,700 acre-feet of water. The annual CBT allocation is typically about 70%.
May 1 is the time of year when the key city water supply factors are the most informative because
the snowpack has usually fully developed by this time, and Boulder’s CBT allotment for the year
has been determined. Those two items combined with current reservoir storage levels provide a
good indication of the city’s available water supply for the coming year. While the May 1 storage
index calculation is still a few weeks away, it is unlikely that water restrictions under the city’s
adopted drought plan will be necessary.
Over any 10 to 20-year period, conditions can vary significantly with a mix of wet and dry years.
In wet years, staff are evaluating short-term opportunities to maximize hydro generation on the
1 The city water utility presently owns 21,000 units of CBT water. A 100 percent quota provides one acre-foot of
water for each unit for that year. The historical average for the annual quota is about 70 percent or 0.7 acre-foot per
unit.
04.15.2019 - WRAB Agenda 7 - Water Supply Update
Page 2
Betasso side of the water system. During dry years, staff are emphasizing water storage
preservation over hydro generation and are making more use of Northern Water sources.
Attachment E shows the variation in use of Boulder Creek and Northern Water supplies on an
annual basis over the last 18 years. More Northern Water supplies were used in drier years (e.g.,
2001-2006, 2012) and in years when maintenance was being conducted on other portions of the
system (e.g., 2016-present) than in wetter years (e.g., 2011, 2014).
One final consideration concerning the city’s water supply relates to the Colorado River, which is
the origin of the city’s CBT (Northern Water) supplies. Staff continues to monitor development of
drought contingency plans (DCPs) among the Colorado River basin states, including Colorado.
The proposed DCPs incentivize proactive water conservation by the states in order to maintain
minimum storage levels in Lake Powell and Lake Mead. These reservoir levels are critical to
water supply in the Western US. Over the next year or so, the state will be leading an effort to
determine steps needed for Colorado’s DCP compliance. It remains to be seen how Northern
supplies might be affected and what that would mean to the city’s water supply. A manageable
temporary reduction may be necessary at some point, and staff will keep WRAB informed as
details become available.
NEXT STEPS:
Staff continuously monitors water supply conditions and will perform the storage index
calculation in early May. As in every year, staff will continue to inform the public of the status of
the water supply and encourage wise water use. The city’s Water Conservation Program helps
coordinate outreach efforts locally and regionally and helps increase outreach efforts if hot, dry
conditions are expected. The Source Water Master Plan includes more detailed information about
management of the city’s water supply. Electronic links to both the city’s Water Conservation
Program and to the City’s Source Water Master Plan can be found in Attachment F.
Also related to water supply, at the October 2018 WRAB meeting, staff presented results from the
first phase of the city’s water supply model update that considered the effects of various climate
change scenarios in the year 2050 on the city’s water supply. In 2019, the city will complete the
next round of modeling that considers climate change scenarios in the year 2070. Once this phase
of modeling is complete, the city will update its drought plan (likely starting in late 2019), with
emphasis on outreach strategies necessary to achieve demand reductions under various drought
scenarios. Staff will provide updates to WRAB during both studies.
ATTACHMENTS:
A – City of Boulder Drought Plan (electronic links)
B – City of Boulder Source Waters
C – Snowpack Data and Colorado Drought Monitor Map
D – City of Boulder Mountain Reservoir Storage Levels
E – City of Boulder Water Supply by Source
F – City of Boulder Conservation Program and Source Water Master Plan (electronic links)
04.15.2019 - WRAB Agenda 7 - Water Supply Update
Page 3
Attachment A
City of Boulder Drought Plan (electronic links)
DROUGHT PLAN - Volume I Drought Planning and Response Plan
DROUGHT PLAN - Volume II Technical Information and Analysis
Attachment A
04.15.2019 - WRAB Agenda 7 - Water Supply Update
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Attachment B
04.15.2019 - WRAB Agenda 7 - Water Supply Update
Page 5
North Boulder Creek Snowpack
Middle Boulder Creek Snowpack
Attachment C – Snowpack Data and U.S. Drought Monitor Map
Attachment C
04.15.2019 - WRAB Agenda 7 - Water Supply Update
Page 6
Statewide Snowpack (Snow Water Equivalent)
Drought Monitor Map
Attachment C
04.15.2019 - WRAB Agenda 7 - Water Supply Update
Page 7
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%Percent FullWY11
WY12
WY13
WY14
WY15
WY16
WY17
WY18
WY19
City of Boulder Mountain Reservoir Storage Levels
WY2011-WY2019
Attachment D - City of Boulder Mountain Reservoir Storage Levels
Attachment D
04.15.2019 - WRAB Agenda 7 - Water Supply Update
Page 8
0
5,000
10,000
15,000
20,000
25,000
30,000
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Avgacre-feetCity of Boulder Water Sources
Northern Water Supply
Boulder Creek Supply
Chart displays both water stored and water
used from each source
Attachment E - City of Boulder Water Supply by Source
Attachment E
04.15.2019 - WRAB Agenda 7 - Water Supply Update
Page 9
Attachment F
City of Boulder Water Conservation Program and Source Water Master Plan (electronic links)
City of Boulder Water Conservation Program
SOURCE WATER MASTER PLAN - Volume 1 Summary Plan
SOURCE WATER MASTER PLAN - Volume 2 Detailed Plan
Attachment F
04.15.2019 - WRAB Agenda 7 - Water Supply Update
Page 10
CITY OF BOULDER
WATER RESOURCES ADVISORY BOARD
AGENDA ITEM
MEETING DATE: April 15, 2019
AGENDA TITLE: Information Item – Boulder Creek E. coli Bacteria Total Maximum
Daily Load Regulatory Update
PRESENTERS:
Jeff Arthur, Director of Public Works for Utilities
Candice Owen, Stormwater Quality Supervisor
Kevin Koryto, Stormwater Quality Engineer
EXECUTIVE SUMMARY:
The City of Boulder Utilities Division has been monitoring Boulder Creek water quality for
several years with a specific focus on bacteria to address the 2011 State-issued Total Maximum
Daily Load (TMDL). Monitoring has focused on many potential contributors of bacteria
including: human sources from untreated sewage due to possible illicit connections to the storm
sewer system; wildlife inhabitance in the storm sewer system; and the potential for bacteria
regeneration in the storm sewer or Boulder Creek system. Bacteria in stormwater is not just a
local issue but also a regional and national issue. Difficulties related to this issue include
determining the type of bacteria (human or non-human), reducing dry weather flows that carry
bacteria in the storm system, and understanding the impacts of urban wildlife on water quality.
This Information Item does not require Water Resource Advisory Board (WRAB) action but is
intended to inform WRAB of the status of the TMDL including the city’s path forward to
identify and mitigate bacteria sources through the implementation of an updated TMDL
Implementation Plan.
BACKGROUND:
Boulder Creek Water Quality and Regulatory Requirements
Under the federal Clean Water Act and State of Colorado Water Quality Control Act, all “waters
of the state”, which includes Boulder Creek, are required to comply with numeric water quality
standards. In 2006, the Colorado Water Quality Control Division (Division) listed Segment 2b of
Boulder Creek (from North Boulder Falls to the confluence with South Boulder Creek) on the
303(d) list for “impaired waters” due to high Escherichia coli (E. coli) bacteria levels. Impaired
waters are bodies of water that fail to meet water quality standards set by the State. E. coli is an
indicator bacteria and most strains are not pathogenic, but it is used to indicate potential fecal
contamination.
04.15.2019 - WRAB Agenda 8 - Boulder Creek TMDL Update
Page 1
Once a water body has been listed as impaired, discharges to the water body are subject to the
development of a TMDL. The primary objective of a TMDL is to calculate the maximum
amount of a pollutant that the water body can assimilate and define what level of pollutant
reduction is required to meet the instream water quality standard. City staff developed a third
party E. coli TMDL which was submitted to the Division and EPA for approval. The TMDL was
approved in September 2011. The reach included in the TMDL was reduced to 13th Street to the
confluence with South Boulder Creek based on additional sampling conducted by the city. The
TMDL includes not only the city, but also the University of Colorado, Boulder County and
Boulder Valley Public Schools, all of which were assigned a wasteload allocation (WLA) or
loading of bacteria allowed to be discharged to the creek and still meet the TMDL.
TMDL Data
Analysis of data collected to support development of the TMDL showed an exceedance of the
state water quality standard from the summer into the fall at monitoring sites from 13th Street
and downstream. See Figure 1. This period is associated with low flows in the creek and is
identified as the target period or critical period (May to October) during which significant E. coli
load reductions are necessary to meet water quality standards. The TMDL anticipates that
meeting the required E. coli reductions during the critical period will result in the protection of
the state designated uses of the creek at all times.
Monitoring data from nine (9) outfalls, which are part of the city’s regulated Municipal Separate
Storm Sewer System (MS4), were also incorporated in the TMDL. These outfalls consistently
had dry weather flow and were identified as a concern through routine monitoring, and in some
cases, citizen complaints. The nine drainages associated with the nine outfalls cover
predominately areas within the City and University of Colorado MS4s. See Figure 2. Based on
the data gathered at these outfalls, the TMDL provided the percent reductions in E. coli
concentrations that would need to be implemented at each outfall, by jurisdiction, to meet the
bacteria water quality standard.
04.15.2019 - WRAB Agenda 8 - Boulder Creek TMDL Update
Page 2
Figure 1 - Geometric mean E. coli data from 2004-2010 at four Boulder Creek Segment 2b
sampling sites. (Note E. - coli standard in red (126 cfu/100 mL)
Figure 2 - Boulder Creek E. coli TMDL Stormsewer Outfall Locations
#######
##1
2 934865730th St9th St28th StPine St
Pearl St
Arapahoe Av
Canyon BvWalnut St
Baseline Rd
Colo rad o Av
BroadwayFolsom StPearl Py
17th StU
S
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y
3
6
M
o
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r
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e
a
d
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v Foo
th
i
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y20th StCollege Av
27th WySpruce St
Mapleton Av
15th StUniversity AvUniversity Av9th St28th StArapahoe Av
Foothills PyBaseline RdBroadway 30th St28th StBr
o
a
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a
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Pearl St Footh
i
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er
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Boulder Creek
0 0.25 0.50.125
Miles
0 0.25 0.50.125
Kilometers
NAD_1983_HARN_StatePlane_Colorado_North_FIPS_0501
Map produced 08-18-2011 by E. Moreno
City of Boulder
Outfalls and Subcatchments
Legend#TMDL Outfalls
MainRoads
303(d) Impaired Segment
Major Streams/Rivers
TMDL Outfall Subcatchments
1
2
3
4
5
6
7
8
9
04.15.2019 - WRAB Agenda 8 - Boulder Creek TMDL Update
Page 3
ANALYSIS:
TMDL Implementation Plan
After approval of the E. coli TMDL, city staff developed a TMDL Implementation Plan. A
TMDL Implementation Plan is not required under State or Federal regulation but is a useful tool
to guide the process of reducing or eliminating bacterial indicators discharged from the city’s
MS4 and help allocate appropriate resources. The initial Implementation Plan was completed in
December 2011 and an updated, more comprehensive, and city specific Implementation Plan will
be completed by the end of April 2019.
The original Implementation Plan was an initial attempt to document potential implementation
actions that the city could consider moving forward through the Stormwater Quality Program.
The Table in Attachment A summarizes the primary activities completed by the City under the
original Implementation Plan.
The original Implementation Plan was helpful to initiate actions related to the mitigation of E.
coli. However, the city determined that the development of an enhanced program that
incorporates state of the science recommendations and experiences from other entities who are
trying to address similar water quality issues would be beneficial.
Updated TMDL Implementation Plan Structure
To help guide the TMDL implementation process the updated Implementation Plan includes
Compliance Principles and a Sequence of Implementation Activities as defined below.
Compliance Principles
Six key principles will guide the city’s activities to comply with the WLAs established by the
TMDL:
• Principle 1 - System-wide Compliance Strategy
Prioritization of outfalls to focus resource allocation and evaluate the efficacy of
reducing bacterial indicator loads from implementation of specific Best Management
Practices (BMPs) activities within an MS4 outfall sewershed (outfall drainage area).
• Principle 2 - Measures of Compliance
The TMDL assumes that if all WLAs and LAs are met (city and others included in the
TMDL) then Segment 2b will attain the E. coli water quality standard, however even if
the city mitigates its controllable sources of bacteria the E. coli water quality standard
may not be attained.
• Principle 3 - Demonstration of TMDL Compliance Through MS4 Permit
The USEPA recommends implementation of a BMP-based approach as the means to
comply with WLAs assigned to urban runoff permitted through an MS4 Permit, as
long as the defined approach includes clear, specific, and measurable elements that
include milestones or other mechanisms to track progress.
04.15.2019 - WRAB Agenda 8 - Boulder Creek TMDL Update
Page 4
• Principle 4 - Critical Condition
The critical condition is the period in time in which the most significant load
reductions are needed to make progress towards attainment of water quality standards
and protection of the recreational beneficial use.
• Principle 5 - Mitigation of Controllable Sources of Bacteria
Mitigating controllable sources of bacteria, in particular anthropogenic sources such as
those attributed to human sources, is the main focus of the Implementation Plan.
• Principle 6 - Jurisdictional Issues/Responsibilities
The city will work collaboratively with the other jurisdictions to reduce bacteria under
dry weather flow conditions. However, the city is not responsible for complying with
WLAs applicable to other jurisdictions.
TMDL Implementation Activities
Key implementation activities outlined below build on the Compliance Principles discussed
above and will guide City efforts to make progress towards meeting the MS4 WLA.
• Water Quality Assessment Activities – Monitoring
to gather water quality data to identify priorities
and support evaluations of progress towards
compliance with the City’s MS4 WLA.
• Tier 1 Prioritization – Prioritization of MS4
outfalls that contribute E. coli bacteria to the
impaired reach. Prioritization will focus on: (1)
risk of exposure to human source bacteria; (2)
mean dry weather flow; (3) E. coli geomean
concentration; and (4) risk to recreational activity.
• Tier 2 Investigation – Identify suite of E. coli
bacteria mitigation activities that may be
implemented within a sewershed that drains to a
Tier 1 prioritized outfall.
• Reporting and Adaptive Management – Periodic
reporting to (1) demonstrate compliance with this
Plan and MS4 Permit requirements; and (2)
document progress towards compliance with the
WLA. As part of this effort, this Plan may be
periodically updated to adapt to changing
understanding regarding bacteria sources.
04.15.2019 - WRAB Agenda 8 - Boulder Creek TMDL Update
Page 5
NEXT STEPS:
The Stormwater Quality Group anticipates beginning to implement the tasks laid out in the
updated Implementation Plan during the Summer of 2019. Activities related to this effort will
likely include conducting storm sewershed investigations and data collection in the University
Hill Neighborhood. Additional activities in 2019 will include investigation into the best
microbial source tracking methods to utilize as part of this investigation.
ATTACHMENTS:
ATTACHMENT A
Attachment A - Summary of City Activities to Mitigate E. coli Under the Initial TMDL
Implementation Plan
04.15.2019 - WRAB Agenda 8 - Boulder Creek TMDL Update
Page 6
Summary of City Activities to Mitigate E. coli Under the Initial TMDL Implementation Plan
No. Program Element Description/Notes Status
1
Robust Illicit
Discharge Detection
and Elimination
(IDDE) Response
Program
Currently implementing program that responds quickly to sanitary or other
instances with potential to discharge E. coli and ensures these are cleaned
up appropriately and before they enter Boulder Creek.
Ongoing
2
Continued E. coli
Instream and Outfall
Monitoring
Continued weekly and monthly monitoring to assess outfall contributions
and instream water quality. Ongoing
3 Slow the Flow Efforts
Facilitates education around reductions in dry weather * flows to the MS4.
Dry weather flows* can carry bacteria from various sources in the City
directly to stormwater outfalls and into Boulder Creek.
Ongoing
4
“Doo Good” Pet
Waste Outreach
Program
Program is implemented through the Keep It Clean Partnership. Includes
collateral and educational materials to educate pet owners on appropriate
pet waste management. Partners include Boulder Valley Humane Society
and City Open Space and Mountain Parks.
Ongoing
5 Pet Waste Stations Continued implementation of pet waste stations along greenways and in
City open space areas. Ongoing
6 MS4 System
Cleaning
Appropriately cleaned and inspected MS4 with outfalls to the TMDL
segment. Cleaning of storm sewer draining to Boulder Creek was
completed in May 2016.
Major efforts
2015-2016;
Ongoing
7 Stormwater
Masterplan Update
Plan addresses MS4 capacity issues throughout the City, but additionally
selects priority locations for water quality improvements. 2016
8
Boulder Creek
Sanitary Main
Investigation
TVed sanitary mains running under Boulder Creek. Discovered no
apparent instances of sanitary mains contributing sewage to the creek. 2016
9 Boulder Creek
Outfalls Survey
Conducted a survey at all MS4 outfalls to Boulder Creek. Visually assessed
potential illicit discharges and conducted water quality sampling for E.
coli, nutrients, and optical brighteners.
2015; 2017;
Ongoing
10
Technical
Memorandum:
Raccoon Storm Drain
Access Control -
University Hill Sub-
Basin
Recommendations
Developed report detailing the feasibility and costs associated with
installing raccoon proofing measures on storm inlets in “The Hill” area of
the city.
2013
11
Marine Street
Raccoon-proofing
Pilot Study
Installed inlet and outfall grates on one small storm sewer line to determine
the impacts on E. coli from raccoons in the system. Observed drastic
reductions in E. coli concentrations. A previous WRAB update on this
topic is located at the following location:
https://documents.bouldercolorado.gov/WebLink/0/doc/121401/Page1.aspx
2012
* Dry weather flows mean that no measurable rainfall has occurred in the area within the previous 72 hours
Attachment A
04.15.2019 - WRAB Agenda 8 - Boulder Creek TMDL Update
Page 7
C I T Y O F B O U L D E R
WATER RESOURCES ADVISORY BOARD
AGENDA ITEM
MEETING DATE: April 15th, 2019
AGENDA TITLE: Information Item – Update on Green Infrastructure Strategic Plan
PRESENTER/S:
Jeff Arthur, Director of Public Works for Utilities
Candice Owen, Stormwater Quality Supervisor
Kevin Koryto, Stormwater Quality Engineer
EXECUTIVE SUMMARY:
The purpose of this memorandum is to update WRAB on the status of the Green Infrastructure
(GI) Strategic Plan (Plan). The Plan was an initiative undertaken by the city to establish a
framework for stormwater quality program policy and program development and to assist with
state stormwater permit compliance. Green infrastructure is defined as the use of vegetated or
media-based stormwater control facilities that promote natural hydrologic processes by treating,
filtering, and infiltrating stormwater runoff.
The primary outcome of the project is a planning document that describes current progress and
future recommendations on stormwater quality program areas. The draft document is in the final
stages of review and is anticipated to be available to the public by the end of April. A key
component of the project was the use of a cross-departmental city staff team of city engineers,
project managers, and subject matter experts. This group provided feedback with respect to city
process, vision, and needs to ensure that recommendations fit with the goals of the city and,
where feasible, in the context of city operations. Staff weighed in on two project focus areas: (1)
stormwater quality process and policy and (2) engineering analysis and prioritized projects.
Project deliverables included updates to the City of Boulder Design and Construction Standards
for stormwater quality, development of standard procedures for stormwater quality design and
maintenance on city projects, and the identification of potential pilot projects where GI could be
effectively installed at city-owned facilities. The Plan also highlights critical next steps such as
development of stormwater quality education and training materials, operations and maintenance
program, and planning for the use of Stormwater Quality capital funds that city staff will
continue working towards implementing during the next several years.
This Information Item does not require WRAB action but is intended to inform WRAB of Plan
progress and outcomes that included stormwater permit updates to the Design and Construction
04.15.2019 - WRAB Agenda 9 - Green Infrastructure Strategic Plan Update
Page 1
Standards, which WRAB approved in February 2019, and planning around uses for water quality
capital funds.
BACKGROUND:
The city’s State-issued Phase II MS4 permit is more prescriptive than the previous permit,
particularly around post-construction water quality. It also expands allowable design options by
providing for a volume reduction or green infrastructure-based design standard. Green
Infrastructure is defined as the use of vegetated or media-based stormwater control facilities that
promote natural hydrologic processes by treating, filtering, and infiltrating stormwater runoff.
Examples of GI include facilities such as rain gardens and vegetated swales/buffers. Benefits of
GI can include water quality treatment of polluted stormwater, reduction of localized (nuisance)
flooding, beautification of urban corridors using vegetation, mitigation of the urban heat island
effect, and public outreach and education on water quality installations.
The Green Infrastructure Strategic Plan was co-funded with the Urban Drainage and Flood
Control District (UDFCD) as an initiative to establish a framework for policy development and
project planning with respect to stormwater quality. The objective of the Plan was to implement
and identify program needs to both comply with the Phase II MS4 permit and promote the use of
sustainable design in the city through the appropriate use of GI. The Plan will also direct a
proactive approach to identifying future stormwater needs and influencing the installation of GI
in the city. Through this project the city is taking a more intentional approach to stormwater
requirements and strategic implementation by making GI the preferred approach to address city
stormwater quality and quantity issues while considering local context.
ANALYSIS:
The Plan is a comprehensive strategy document for the city to address GI on both private and
capital projects. The Plan focuses on two project areas: (1) stormwater quality process and policy
and (2) engineering analysis and prioritized projects. The project was city led with the financial
and technical assistance of UDFCD and an engineering consultant. The project included a series
of five staff team meetings to provide input on progress and direction and to ensure
recommendations considered city specific context and concerns.
Internal Staff Engagement
A primary objective of the project was to develop a plan that accounted for the unique concerns,
constraints, and opportunities presented in Boulder. The project leveraged a cross-department
team of city engineers, managers, and subject matter experts to both create workable solutions
and foster collaboration and acceptance of recommended strategies for city projects. City
departments and groups represented on the staff team included:
• Facilities Asset Management
• Open Space and Mountain Parks
• Parks and Recreation
• Public Works - Transportation Engineering
• Public Works – Transportation Maintenance
04.15.2019 - WRAB Agenda 9 - Green Infrastructure Strategic Plan Update
Page 2
• Public Works - Utilities Engineering
• Public Works – Utilities Maintenance
• Public Works – Planning and Development Services
• Parks and Recreation
• Public Works – Utilities – Water Quality and Environmental Services
• Urban Drainage Flood Control District
The staff team provided high-level input, overall program visioning, and assisted in the
development of specific strategies for engagement of external stakeholders, city administration,
and the general public to address permit compliance policy questions and build support for the
GI/stormwater program.
The end result of the staff engagement process was greater support from city staff and
momentum to implement city project recommendations moving forward. Feedback from the staff
team indicated that they greatly valued the opportunity to contribute to the direction of the
project, felt their input was incorporated into outcomes, and would like the opportunity to
contribute to the direction of the stormwater/GI program in the future.
Process and Policy
The objective of the process and policy task was to develop strategies for the integration of post-
construction stormwater management program elements, including low impact development
(LID) principles and GI, into city process in keeping with the MS4 permit and city goals.
Primary work products completed as a part of this area of the Plan include:
1. Boulder Design and Construction Standards Revisions for Water Quality: In
February of 2019 WRAB was presented with and recommended for approval by City
Council, proposed changes to DCS sections for Post-Construction Stormwater Quality
Requirements. These changes were developed as part of this project and take into
consideration MS4 Permit requirements and goals to address pollutants of greatest
concern using GI. The revised DCS has specified criteria for considering onsite
infiltration conditions to select a water quality design that is most appropriate for the site
and reduces the risk of control measure failure.
2. Standard Procedures for Stormwater Quality on Public Projects: A series of
interdepartmental operating procedure documents was created that establishes standard
protocols for the planning, design, construction, and maintenance of stormwater quality
facilities. These documents are being used to conduct trainings with city staff to ensure
that all city projects follow standard procedures for permit compliance and consider GI
where appropriate.
Engineering Analysis and Prioritized Projects
The objective of the engineering analysis and prioritized projects task was to identify potential
pilot projects where the city could demonstrate the implementation of GI policies and design.
This task was initiated by the development of a tool to prioritize potential projects. The staff
team provided input to assist with identifying and vetting potential projects and prioritizing
04.15.2019 - WRAB Agenda 9 - Green Infrastructure Strategic Plan Update
Page 3
scoring criteria used in project evaluation. Pilot project identification included an assessment of
project types including upcoming CIP projects and GI specific installations (prioritized city
facilities and maintenance initiatives).
Evaluation and prioritization of these project types led to the selection of seven potential
installation locations. Preliminary/planning level designs were completed and presented to the
staff team. Based on staff feedback, one planning level design was further refined to a concept
design plan with an associated cost estimate and details.
NEXT STEPS:
The Plan is the framework for continued efforts by the city to develop a robust MS4 compliance
and GI implementation program. The Plan is the starting point for several continuing and future
efforts related to stormwater quality. Key next steps highlighted in the Plan include:
1. Continued City Staff Team Engagement: City staff will utilize the city staff team
created as part of this project to evaluate progress and guide future efforts with regards to
water quality compliance and GI in the city.
2. Stormwater Quality Education and Training: City staff will plan and develop
trainings and outreach materials for the public and city staff with regards to the planning,
design, and maintenance of effective stormwater control measures.
3. Operations and Maintenance Program Development: City staff will collect data,
utilize asset management software, provide training, and coordinate inspection and
maintenance activities for city-managed stormwater control measures.
4. Water Quality Capital Funds Planning Framework: City staff will continue to work
towards planning the use of water quality CIP funds and prioritizing projects and
initiatives that provide the greatest benefit to the public and stormwater quality.
04.15.2019 - WRAB Agenda 9 - Green Infrastructure Strategic Plan Update
Page 4
CITY OF BOULDER
WATER RESOURCES ADVISORY BOARD
AGENDA ITEM
MEETING DATE: April 15, 2019
AGENDA TITLE: Information Item – Rate Structure Implementation Update
PRESENTERS:
Jeff Arthur, Director of Public Works for Utilities
Ken Baird, Senior Financial Manager, Public Works
Justin Greene, Financial Analyst, Utilities
EXECUTIVE SUMMARY
This agenda item is intended to provide WRAB with an update related to the impacts of rate
structure changes that began in 2018 for water, wastewater, and stormwater/flood rates. With
2018 usage and revenue data now available, analysis has been performed to review the extent to
which the goals of the rate structure changes are being met.
BACKGROUND
In 2015, Utilities Division staff began a project to analyze and potentially recommend changes to
the rate structures of the city’s three utilities. There were two main reasons this analysis. First,
the Utilities Division periodically reviews its rate setting methodology to assure that utility rates
are meeting community goals and are aligned with fee-based principles. Second, during 2014,
Utilities staff met with customers to better understand the impacts of proposed 2015 utility rate
increases. Many customers indicated they did not understand utility rate structures and/or had
questions and concerns about the calculation of the charges on their utility bills.
City staff worked with a contracted rate consultant to review the rate structures and make
recommendations. This process included public input through open houses, a survey, and
working closely with WRAB. Through this process, WRAB recommended the following
Guiding Principles to speak to what the rate structures should be designed to accomplish.
04.15.2019 - WRAB Agenda 10 - Rate Structure Implementation Update
Page 1
The recommended rate structure changes were reviewed by City Council at their May 2, 2017
meeting and approved through the adoption of the 2018 budget. The agenda for that meeting is
found in Attachment A for more background and context. The rate structure changes were the
following:
•Move Commercial/Industrial/Institutional (CII) customers with an Average Monthly
Usage water budget to the existing “CII Indoor/Outdoor” budget methodology, which
will be renamed “CII AWC”
•Reduce the single-family residential indoor water budget by 1,000 gallons per month
•Adjust the wastewater rate structure so that the fixed portion of the fee will account for
25 percent of billed revenues in the wastewater fund, and also adjust rates to account for
declining wastewater usage
•Adjust the stormwater/flood management rate structure to include a fixed charge and a
charge based on impervious area.
The impact of these changes based on one year of data will be discussed below.
ANALYSIS
One of the two key changes to the water rates involved adjusting how CII customers water
budgets are calculated. Prior to 2018, most CII customer’s water budgets were determined using
the Average Monthly Usage (AMU) methodology. AMU budgets were based on outdated 2005
usage data and resulted in overly generous budgets for some customers and unnecessarily
restrictive budgets for other customers. This was addressed by updating the customers with an
AMU water budget to methodology called CII AWC, which uses the customers most recent
Average Winter Consumption as the basis for setting the water budget.
The goal of this change was for increased equity within the class, by making customer’s water
budget more closely aligned with their current usage. One way to measure this is to divide the
whole CII class water budget by the actual water usage. The closer the result is to 100%, the
more closely aligned will be the budget and usage. The charts below show this ratio each month
for 2017 and 2018. While many months in 2017 were closer to 80% to 90%, the 2018 ratios
were closer to 100%. The average fit in all the months in 2017 was 91.5%, and in 2018 the
average was 98.5%.
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Another way to understand the impact of this change is to look at two CII customers who
received an adjustment to their water budget through this structure change. Customer A is a nail
salon that had a monthly water budget of around 2,000 gallons per month in 2017, resulting in
upper block charges to most of the usage. Adjusting the budget based on AWC resulted in a
budget of around 10,000 gallons per month, which is a better reflection of current usage.
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Customer A – 2017 Budget and Usage
Customer A – 2018 Budget and Usage
Customer B is a small grocer/deli on the Hill with a 2017 monthly water budget around 55,000
gallons per month. With the 2018 structure changes, their water budget was adjusted to around
10,000 gallons per month. Their average monthly water charge increased around 16% and was
more consistent with their usage. As shown in their 2018 graph below, it appears they had a leak
in November which resulted in a relatively high bill due to 19,000 gallons being charged in
blocks three through five. If they still had their 55,000 gallon water budget in 2017, even with
this leak they would have still been within their water budget and may not have received the
price signal alerting them to address the leak.
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Customer B – 2017 Budget and Usage
Customer B – 2018 Budget and Usage
The other key change in the water rate structure involved the single-family detached (SFD)
customer class. The indoor water budget for this class had been 7,000 gallons per month. There
has been a trend over the years of decreasing indoor water usage, so that the class average indoor
usage is closer to 4,000 gallons. Through the rate study, the indoor budget for SFD was adjusted
to 6,000 gallons. Looking at the 2018 data, analysis was performed on the usage impact within
this class and also looking at the revenue impact of this change.
One of the intents of the water budget rate structure is to send a price or behavioral message to
encourage efficient water use. There would come a point where customers would use less water
as a result of being charged more or possibly by being told they are using more than their budget.
As noted in the January WRAB year-in-review memo, it does not appear that adjusting the SFD
indoor budget to 6,000 gallons per month had a significant impact on usage. The 2018 SFD
average winter consumption – an indicator of indoor usage – was down 1.6% compared to 2017.
This AWC reduction is inline with the ongoing downward trend the utility has been experiencing
for many years. It is also important to note, it is challenging to isolate the impact of a minor
change to the rate structure, and more years of data may help to identify impacts.
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The revenue impact of the SFD indoor budget change is simpler to calculate. Lowering the
water budget means that more consumption will fall in higher rate blocks, which results in
increased revenue. Looking at 2018 usage and revenue data for the single-family class, there
was around $210,000 in additional revenue as a result of this change. Receiving additional
revenue as a result of this change was anticipated and factored into the rate calculation process.
Given that the 6,000 gallon per month indoor budget is still above the average winter
consumption amount for SFD of 4,000, further reductions to the indoor budget may be
considered in the future. If the budget had been reduced to 5,000 instead of 6,000 gallons the
additional revenue would have around $500,000 instead of $210,000.
The rate structure change included one significant change related to the wastewater charge. This
related to addressing revenue insufficiency due to annual declining volume sales and the amount
of revenue recovered through the monthly service charge. Rates for 2018 were adjusted so that
funds received from the fixed service charge resulted in 26% of total billed revenue. The target
through the structure change was 25%. Also, wastewater billed revenue met the 2018 revenue
projection for the first time in five years.
Finally, the change in the stormwater/flood rate structure involved simplifying the rate formula
for non-SFD accounts. The old rate used the factors of total area, pervious area, impervious area,
and runoff coefficient. The new rate changed to a fixed billing charge and a charge per square
foot of impervious area. This not only met the goal of simplifying the rate, but also
acknowledging the benefit that pervious area has to the stormwater system by charging only for
impervious area.
NEXT STEPS
WRAB will be discussing the 2020-2025 Utilities Capital Improvement program (CIP) and
associated rate impacts at the upcoming May, June, and July meetings. Along with the CIP,
WRAB provides a recommendation related to rate changes, so
Attachment A: Utility Rate Structures Study Update May 2, 2017 Agenda Memo
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CITY OF BOULDER
CITY COUNCIL AGENDA ITEM
MEETING DATE: May 2, 2017
AGENDA TITLE: Utility Rate Structures Study Update
PRESENTER/S
Jane S. Brautigam, City Manager
Maureen Rait, Executive Director of Public Works
Jeff Arthur, Director of Public Works for Utilities
Ken Baird, Utilities Financial Manager
EXECUTIVE SUMMARY
The purpose of this agenda item is to provide an update to City Council regarding
changes to the Water, Wastewater, and Stormwater/Flood Management rate structures in
the 2018 budget. The changes, if adopted, would take effect Jan. 1, 2018.
In 2015, Utilities Division staff began a project to analyze and potentially recommend
changes to the rate structures of the city’s three utilities. There were two main reasons for
such an analysis. First, the Utilities Division periodically reviews its rate setting
methodology to assure that utility rates are meeting community goals and are aligned
with fee-based principles. Second, during 2014, Utilities staff met with customers to
better understand the impacts of proposed 2015 utility rate increases. Many customers
indicated they did not understand utility rate structures and/or had questions and concerns
about the calculation of the charges on their utility bills.
A public engagement process during spring of 2015 included the city mailing 26,000
postcards to notify customers of the opportunity to provide input. The resulting feedback
did not indicate the need to make largescale changes to the rate structures. Staff and
consultant analysis during 2015 and 2016 identified the following key issues across the
three rate structures:
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Components of the water budget rate structure, such as how the pricing blocks
and residential indoor budgets are set, are resulting in unclear pricing signals for
water conservation purposes.
Water budgets, as currently designed, do not work well for commercial, industrial
and institutional (CII) customers. This is due to such diverse usage among CII
accounts which makes it challenging to set individualized budgets for each
customer.
Because of issues within the current water budget rate structure, both those
described above and others, the utility funds are experiencing weather-dependent
revenue instability and unpredictability.
The wastewater utility is facing revenue instability and unpredictability because
its fixed service charge is set too low, and it is too dependent on the volume of
wastewater usage, especially when compared to other peer utilities in Colorado.
Under the current stormwater monthly fee calculation, which uses the same basic
methodology across all customer classes, customers other than single-family
residential (SFR) are assessed charges based on the ratios of their lot size and
impervious area to a typical SFR lot. One result of this approach is that the benefit
of a large amount of land that absorbs stormwater is outweighed by the large size
of the lot. Counterintuitively, the former is often canceled out by the latter. A
different methodology might better account for the unique characteristics of
atypical, large-lot properties that are mostly grass.
After numerous Water Resources Advisory Board (WRAB) discussions about the nature
of these issues and the best way to address them, the board has provided a
recommendation for specific rate structure adjustments. At its March 20, 2017 meeting,
WRAB unanimously approved the following motion:
The Water Resources Advisory Board recommends implementing the following changes
to the utility rate structures, to be effective Jan. 1, 2018:
Move Commercial/Industrial/Institutional customers with an Average Monthly Usage
water budget to the existing “CII Indoor/Outdoor” budget methodology, which will be
renamed “CII AWC”
Reduce the single-family residential indoor water budget by 1,000 gallons per month
Adjust the wastewater rate structure so that the fixed portion of the fee will account for
25 percent of billed revenues in the wastewater fund, and also adjust rates to account
for declining wastewater usage
Adjust the stormwater/flood management rate structure to include a fixed charge and a
charge based on impervious area.
Overall, the recommended rate structure changes would help discourage wasteful use,
increase revenue stability and increase equity. As a result of these changes, some
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customers would experience bill increases, and while others would see lower bills. Low-
volume SFR users would see an increase of around $5 or $6 per month. The CII
customers that would see the largest bill increases are those that have both mostly
impervious surface (such as buildings and parking lots that do not absorb stormwater)
and a water budget that is higher than their current usage. In anticipation of these changes
in January 2018, staff would conduct customer outreach utility-wide regarding these
changes, and targeted outreach to the CII customers most affected.
COMMUNITY SUSTAINABILITY ASSESSMENTS AND IMPACTS
Economic – In addition to meeting the financial needs of the three utilities, the
rate structures must take into account the financial needs of households and the
business community.
Environmental - The rate structures are a tool in helping the Utilities Division
meet the community’s environmental goals, especially related to water
conservation. The proposed adjustments seek to ensure that rate structures are
aligned with city goals related to water conservation and water quality.
Social - The provision of utilities services is a foundational building block of
community life. In addition, equity and the impact of the rate structures across
customer classes will be an important consideration.
BOARD AND COMMISSION FEEDBACK
The Water Resources Advisory Board supported the recommended rate structure changes
in their motion with a vote of five to zero.
PUBLIC FEEDBACK
Public outreach efforts are described below in the background section. Staff received
limited public input despite outreach efforts. Themes of the feedback received included
confusion regarding how bills are calculated, support for changes to the stormwater rate
to encourage improvements that decrease stormwater impacts, and a desire for more
stability in customer monthly bills.
BACKGROUND
In 2014, Utilities Division staff met with customers to better understand the impacts of
proposed 2015 utility rate increases. Many customers indicated they did not understand
utility rate structures and/or had questions and concerns about the calculation of the
charges on their utility bills.
The Utilities Division periodically reviews its rate setting methodology to assure that
utility rates are meeting community goals and are aligned with fee-based principles.
These findings led staff to propose an evaluation of the rate structure and associated
calculations for water, wastewater and stormwater/flood management utilities as part of
the 2015 work plan. As a first step, the city implemented a public engagement process to
solicit broader feedback across all customer classes. The initial public engagement
process took place in April and May 2015, and consisted of three open houses and an
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online survey. More than 26,000 postcards were mailed to utilities customers to notify
them about the engagement opportunities.
In June 2015, staff presented to WRAB the results of the public engagement process, as
well as options for the Utility Rate Study’s guiding principles and its areas of study (the
June 2015 packet can be found here). Guiding principles are high-level goals and speak
to what the rate structures should be designed to accomplish. Feedback collected during
the public engagement process did not indicate a desire to change the five existing
guiding principles for the water rate structure. WRAB recommended that the guiding
principles should apply not only to water, but also to the other two utilities. In addition, it
was determined that the stormwater/flood management utility should have a guiding
principle specifically encouraging development that minimizes stormwater impacts.
These discussions resulted in recommended guiding principles and their application
across the three utilities, as shown in the following table.
Table 1 – Adopted Rate Guiding Principles
Principle Water
Utility
Wastewater
Utility
Stormwater/Flood
Management Utility
Discourage wasteful use, while promoting all justified types and
amounts of use. X
Be effective in yielding total revenue requirements. X X X
Provide revenue stability and predictability for the utilities. X X X
Fairly allocate the total cost of service across customer classes to
attain equity. X X X
Be dynamic and proactive to address changing supply and
demand conditions, as well as the city’s sustainability and
resilience goals.
X
Encourage low-impact development to decrease stormwater
impacts. X
During the same meeting, WRAB also agreed with the project’s following suggested
areas of study. The original areas of study included:
Stormwater/Flood Management Calculation Methodology
Effectiveness of Water Budgets
Fixed vs. Variable Charges
Cost of Service
Outside City vs. Inside City Rates
As the evaluation began, the exact nature of the areas of study evolved and the focus
narrowed, resulting in areas of study more specifically defined as key issues. For
example, a detailed revisiting of Outside vs. Inside City Rates was ultimately a lower
priority than other items for this project. Consultant analysis indicated that the outside
city multiplier is similar to an approach used by other communities. The other key issues
are described in more detail later in the memo.
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Following the June 2015 meeting and discussion, staff prepared and distributed an
Information Packet memorandum to update City Council on the project’s progress. Based
on WRAB feedback and guidance related to guiding principles and areas of study, staff
developed a scope of work for the analysis phase of the project. The scope of work
informed a request for consultant proposals (RFP), which was issued in early November
2015. Staff received four complete proposals and selected Denver-based Raftelis
Financial Consultants (RFC) to assist with the project.
The analysis component of the project was roughly divided into three phases, as follows:
Phase 1 – Investigation and Assessment
RFC assisted the staff in comprehensively understanding what was happening within the
rate structures and the pros and cons of the current systems. The consultant team and staff
presented these preliminary findings to WRAB at the August 2016 meeting. WRAB’s
feedback helped determine which identified issues required a new approach within the
rate structures.
Phase 2 – Analysis of Potential Alternatives
Based on WRAB feedback at the August, September and October meetings, RFC
developed and analyzed options to address issues identified in the first phase.
Alternatives were developed and tested across all three utilities and all customer classes
and bill impacts were calculated. Staff and RFC presented the results of the options
analyses at the January and February 2017 meetings.
Phase 3 – Recommendations
Based on the results of the second phase and WRAB discussion in January and February
2017, staff and RFC refined the analysis and WRAB provided recommendations to City
Council.
Findings: Key Utility Rate Structure Issues
The analysis completed by staff and RFC in Phase 1 revealed several findings, the most
significant of which are summarized below.
The key findings and supporting analysis were all developed through the filter of the
guiding principles. Where applicable for each area of study, RFC explored questions of
revenue sufficiency and stability, water conservation, customer equity and other go als
inherent in the guiding principles. What follows are key issues RFC identified for each
area:
Water Utility, including Water Budgets
RFC identified the following five key issues relative to the existing water utility rate
structure:
1.Water budget rate structures do not work well for commercial, industrial and
institutional (CII) customers. This is due to such diverse usage among CII
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accounts which makes it challenging to set individualized budgets for each
customer.
2.Blocks 1 and 2 could be combined into a single block to provide for more
consistent monthly water budgets. Alternatively, a modified definition could be
applied where, quite simply, block 1 is defined as the indoor budget and block 2
as the outdoor budget.
3.Residential indoor water allocations exceed recent indoor water use.
4.Reliance on revenue generated in Blocks 3, 4 and 5 results in a level of revenue
instability that could adversely impact utility operations.
5.Block width and block pricing may not be aligned with city pricing objectives.
Wastewater Utility
RFC identified the following two key issues relative to the existing wastewater utility rate
structure:
1.Revenue insufficiency exists due to:
a.declining volume sales and
b.amount of revenue recovered through monthly service charge.
2.Industrial Pre-Treatment fees do not recover the costs incurred.
Stormwater/Flood Management Utility
RFC identified the following two key issues relative to the existing stormwater utility rate
structure:
1.Non-single family rate structure is unnecessarily complex.
2.The current rate structure undervalues the benefit of a large amount of land that
absorbs stormwater. Impervious area (where the ground cannot absorb water)
creates stormwater impacts during storm events as water runs off the surfaces. But
large lot customers with large amounts of pervious area (where the ground can
absorb water) do not proportionally benefit from their ability to absorb water
during a storm event.
Additional Considerations
During the project, a number of additional items were raised as potential areas of
exploration. As WRAB periodically discussed these additional topics, it was determined
that each fell outside the scope of the rate study, but could be considered in the future.
The additional topics considered by WRAB and the team are as follows:
Affordability
WRAB discussed whether affordability should be considered more heavily in the rate
structure. In particular, there was a potential concern that those with the lowest utility
bills (i.e., those who use the least amount of water) could see some of the largest
increases relative to their current bill if fixed service charges were to increase. However,
water and wastewater volume use does not correlate with income, and so low-volume
customers cannot be assumed to have low incomes. In addition, affordability is not one of
the guiding principles for the utility rate structure, nor is it known to be an issue for low-
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income utility customers in Boulder. Research suggests that water, wastewater and
stormwater utility bills are only a small portion of most household budgets, regardless of
income. And, for those who do struggle to pay their bills, assistance is available from
social service providers. Staff shared information with WRAB about affordability issues
and programs at the December 2016 meeting.
More Aggressive Water Conservation
Questions emerged during the project about the effectiveness of current water budget
levels and related pricing signals. WRAB was supportive of some rate structure
adjustments that would strengthen the price signal, but also acknowledged that the city is
in the process of a climate modeling and water conservation needs analysis that will help
determine the city’s overall conservation goals for the future. That work, and subsequent
policy discussions by WRAB and City Council, will inform future decisions about water
conservation goals and how they should be pursued through water budgets or other
conservation mechanisms.
Fundamental Restructuring
Understanding that the current water rate structure does not perfectly address all guiding
principles, or other utility goals, WRAB asked whether the city might pursue a wholly
different structure. Besides the ongoing work on future conservation needs mentioned
above, there are other reasons to put off such a decision into the future. Chief among
them is that the city’s current meter technology and billing infrastructure is
approximately 15 years old and the state of the art is changing all the time. A
fundamentally new rate structure, while attractive in concept, may not currently be
supportable by existing city technology. Staff suggested that the city explore alternative
rate structures in conjunction with a future meter replacement project. New applications
of technology, such as real-time data reporting, may support future innovation in water
pricing and customer communication. Recognizing these realities, WRAB maintained the
scope of the project as a collection of smaller adjustments, which was also in keeping
with public feedback received during the 2015 public engagement process. The city will
also be upgrading to a new customer billing portal in 2018, which may create
opportunities for enhanced communication with customers.
ANALYSIS
Alternatives Developed to Address Key Issues
At their September and October 2016 meetings, WRAB confirmed the key issues as the
right ones to address. The board also expressed support for alternatives that staff and
RFC should explore in order to address the key issues.
Water Utility, Including Water Budgets
In the water utility, RFC’s Phase 1 analysis indicated that the following issues were the
most important to address:
1.Water budgets do not work well for diverse Commercial, Industrial, Institutional
(CII) customers. This is especially true of those customers using the Average
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Monthly Usage (AMU) methodology to determine their budgets. AMU budgets
are based on outdated 2005 usage data that results in overly generous budgets for
some customers and unnecessarily restrictive budgets for other customers.
2.Block 1 of the rate structure sends an inconsistent pricing message for single-
family residential (SFR) customers. For example, in the winter months a portion
of indoor use can be priced at Block 2, and in the summer months all indoor use is
priced at Block 1
3.Residential indoor water allocations exceed recent indoor water use, indicating
that residential water budgets may be set in such a way as to undermine some
utility goals.
4.Reliance on revenue generated in Blocks 3, 4 and 5, which are considered “out of
budget” blocks and represent levels of water use that customers should not
regularly be reaching, results in a level of revenue instability that could adversely
impact utility operations.
Staff and RFC developed an alternative in which small adjustments to existing rate
structure components, when taken together as a package, work to improve upon the
issues listed above. This alternative, when compared to the status quo structure (which
includes a projected, but not approved, 8 percent rate increase for 2018), improves
revenue stability and predictability, increases equity within and between customer
classes, maintains the water budget rate structure to discourage wasteful use, and also
promotes justified use by better aligning CII water budgets with expected efficient use.
The main components of the alternative included:
Increasing the fixed service charge to better reflect costs of service.
Combining the existing Blocks 1 and 2 to eliminate an unclear price signal and
improve revenue stability
Decreasing the residential indoor allocation, which regularly exceeds actual
indoor use. SFR would be reduced from 7,000 gallons to 6,000 and MFR would
be reduced from 4,000 to 3,000.
Moving existing CII customers using the AMU water budget category to the
Indoor/Outdoor category to better align budgets with normal use.
Staff analysis and subsequent WRAB discussion supported the idea that increasing the
fixed charge and combining the first two blocks would not increase revenue stability and
predictability to a great enough degree to outweigh the impacts of such changes.
However, WRAB supported a reduction in the single-family residential indoor allocation
and the movement of existing CII AMU customers to the Indoor/Outdoor water budget
option. The reasoning behind lowering the indoor allocation is to better align budgets
with actual use and to strengthen the conservation pricing signal.
The current recommendation is to reduce only the SFR indoor allocation from 7,000 to
6,000 gallons, and keep the MFR per unit indoor allocation at 4,000 gallons. As shown in
Figure 1 below, SFR indoor budget is two times the average usage, while MFR indoor
budget is 1.6 times average usage. If MFR indoor budgets are lowered in the same
amount as SFR, then MFR customers will more often exceed those budgets and pay
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higher volume rates in the out-of-budget pricing blocks. Reducing only the SFR indoor
budget by 1,000 (which would make the budget 6,000 gallons or approximately 1.75
times average usage) brings these two classes more in line with each other with indoor
use relative to indoor budget.
Figure 1 – Average Indoor Use vs. Budget for SFR and MFR Customers (2015)
Wastewater Utility
The residential charges for wastewater quantity, or volume, are billed using actual water
use or Average Winter Consumption (AWC), whichever is less. AWC means the average
water use per month during the most recent December through March time period. Non-
residential customers are billed for wastewater quantity charges based on actual use or
indoor water budget allocation depending on their selected water budget option. The
rationale for using winter water use as a basis for wastewater charges is that winter water
use is an accurate approximation of how much wastewater is produced. In other words,
nearly all water used in the winter is used indoors and therefore eventually finds its way
down the drain or flushed down a toilet. As water-using fixtures and appliances, such as
shower heads, toilets, washing machines, and dishwashers, have become more efficient
over time, they are able to send the same amount of waste into the system with much less
water. The wastewater system’s costs of operation do not decline with less water use
because the system must still treat the same amount of waste, even if less water is used to
move the waste through the system. In fact, the vast majority of the wastewater utility’s
costs are fixed.
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RFC’s Phase 1 analysis identified an issue of revenue insufficiency due to declining
volume sales and amount of revenue recovered through the monthly service charge. The
decrease in indoor water use due to more efficient fixtures and appliances has meant less
volume revenue for the wastewater utility. To address this, RFC proposed the following
four wastewater rate structure alternatives for consideration. All alternatives incorporated
an assumed 2 percent per year decrease in billed volumes per account, consistent with
recent trends, while accounting for future revenue needs projected in the utilit y’s
financial planning. The alternatives aim to recover the same total amount of revenue, so
an increase to the fixed service charge will result in a decrease to the volume rate.
1.Increase rates sufficiently to address declining wastewater use and sales, but leave
the existing structure itself intact.
2.Increase the fixed service charge sufficiently to recover fixed customer costs.
Decrease the volume rate accordingly.
3.Increase the fixed service charge to recover 25 percent of annual user charge
revenue. Decrease the volume rate accordingly.
4.Increase the fixed service charge to recover 50 percent of annual user charge
revenue. Decrease the volume rate accordingly.
The potential need to increase rates more than previously projected to compensate for
declining wastewater volume will be addressed through the annual budget and rate-
setting process.
As for the structural increase in the fixed service charge, WRAB considered alternatives
at three levels: cost of service based (Alt 2, approximately 13 percent of total user
revenues), 25 percent of total user revenues (Alt. 3), or 50 percent of total user revenues
(Alt. 4). The chart below illustrates where any of the alternatives would place the city’s
fixed charge for a ¾ inch residential water meter customer in relation to peer utilities.
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Figure 2 – 2017 Fixed Service Charge and 2018 Alternatives, Boulder vs. Peer
Utilities
In order to increase revenue stability for the utility, WRAB supported increasing the fixed
charge to a level that would recover 25 percent of revenues (Alt. 3). The most significant
impact of such a change would be to the lowest volume wastewater customers. As the
fixed charge increases, and the volume rate decreases accordingly, the existing financial
benefit of using a low volume of wastewater decreases. Under WRAB’s preferred
alternative, a low-volume customer who is billed for 2,000 gallons of wastewater use
would have a bill of $21.18 instead of $15.58, which is the projected monthly charge if
no change is made. This outcome is equitable for two reasons. First, as described above,
the cost for waste treatment does not depend on the amount of water used. Second, the
vast majority of wastewater system costs are fixed, and each customer should pay a fixed
charge in recognition of that reality.
The analysis also found that fees in the Industrial Pre-Treatment program were not
recovering the full program costs. Cost recovery in the program is not a policy issue. It
will be addressed through the 2018 budget and related fee setting process.
Stormwater/Flood Management Utility
RFC identified the following two key issues relative to the existing stormwater utility rate
structure:
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1.The non-single family rate structure is unnecessarily complex.
2.The current rate structure undervalues the benefit of a large amount of land that
absorbs stormwater. Impervious area (where the ground cannot absorb water)
creates stormwater impacts during storm events as water runs off the surfaces. But
large lot customers with large amounts of pervious area (where the ground can
absorb water) do not proportionally benefit from their ability to absorb water
during a storm event.
RFC proposed the following three stormwater rate structure alternatives for
consideration. All alternatives incorporated modifications to address large lot and
atypical properties while accounting for future revenue needs projected in the utility’s
financial planning documents.
1.Simplify the formula for clarity but leave the structure unchanged; address
atypical large lot customers with large amounts of pervious area through credit
policies.
2.Change the fee calculation to include only a fixed charge (reflecting billing costs)
and a charge based on impervious area.
3.Change the fee calculation to include a fixed charge (reflecting billing costs) and
a formula incorporating both pervious and impervious area.
The table below provides projected rates, which reflect projected revenue needs in 2018,
under the three alternatives.
Table 3 – Projected SFR Stormwater Rates
Table 4 – Projected Non-SFR Rates
Size of Parcel 2017 Alt. 1 – Status
Quo
Alt. 2 – Fixed
and Impervious
Area Charge
Alt. 3 – Fixed,
Impervious and
Pervious Area
Charge
Up to 15,000 sq. ft. $15.12 $16.40 $15.61 $17.99
15,000 to 30,000 sq. ft. 18.89 20.50 18.89 21.87
30,000 sq. ft. or more 22.69 24.60 22.17 25.74
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Staff and WRAB were in agreement that an unchanged rate structure with a credit system
to address atypical large lot customers was not a preferred option. It would represent a
“work around” instead of fundamentally addressing the structural issue and would add
complexity to an already complex method of determining stormwater/flood management
charges.
Of the remaining alternatives, WRAB recommended Alt.2, which is calculated based on
a fixed charge and an impervious area charge. This alternative removes pervious area
from the fee calculation in recognition of the fact that pervious area has less of a
stormwater and flood impact than impervious area. Under the alternative, all customers
are charged on the same basis, with a fixed charge of $2.50 (for fixed costs regardless of
customer property characteristics) and an area charge of $5.70 per 1,000 square feet of
impervious area. Similar to the existing rate structure, the SFR class has three tiers to
account for the small number of customers with larger property sizes.
Non-SFR customers with the largest amounts of impervious area (such as large parking
lots) would experience the largest bill increases. In general, large lot customers with large
amounts of pervious surface (such as large areas of grass) would experience a bill
decrease. This alternative would minimize impact to SFR customers as their bills would
be slightly lower compared to the status quo alternative.
The table below describes how different types of customers would fare under the
preferred alternative.
Table 5 – 2018 Monthly Impacts for Different Customer Types, Status Quo vs. Alternative
Customer Type (impervious area) 2017 Current 2018 Status Quo 2018 Alt.
Single Family Residential (2,300 sq. ft) $15.12 $16.33 $15.61
Shopping Center with Large Parking Lot
(380,000 sq. ft.)
$1,800 $1,900 $2,200
Large Industrial with a lot of greenspace
(390,000 sq. ft.)
$3,200 $3,500 $2,200
Size of Parcel 2017 Alt. 1 –
Status Quo
Alt. 2 – Fixed
and Impervious
Area Charge
Alt. 3 – Fixed,
Impervious and
Pervious Area
Charge
Base Rate $15.12 $16.40 N/A N/A
Fixed Charge N/A N/A $2.50 $2.50
Impervious Area Charge
(per 1,000 sq ft impervious area unit) N/A N/A 5.70 4.65
Pervious Area Charge
(per 1,000 sq ft pervious area unit) N/A N/A N/A 1.02
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Urban Agricultural $490 $530 $100
Total Bill Impacts of Preferred Alternatives
In summary, the recommended alternatives are as follows:
1.In the water rate structure, the indoor allocation for SFR customers will be
reduced by 1,000 gallons and all existing CII AMU customers would be moved to
the Indoor/Outdoor budget methodology.
2.In the wastewater rate structure, the fixed service charge would be increased to an
amount sufficient to recover 25 percent of user charge revenues.
3.In the stormwater/flood management rate structure, the fee calculation
methodology for non-SFR customers would be changed to include only a fixed
charge and a charge for each square foot of impervious area.
For the SFR class, the main impact is for low volume users who will experience an
increase in the fixed wastewater charge without an offsetting reduction in the volume
charge, due to their low use. The impact may be somewhat mitigated by the reduction in
the stormwater/flood management fee.
Table 6 – Total Monthly Impacts for Average Single Family Customer, January and July
January – 5,000 Gallons 2018 Status Quo 2018 Alt.
Water $28.33 $28.13
Wastewater $36.37 $37.44
Stormwater $16.33 $15.61
Total $81.03 $81.18
July – 20,000 Gallons 2018 Status Quo 2018 Alt.
Water $79.99 $79.16
Wastewater $36.37 $37.44
Stormwater $16.33 $15.61
Total $132.69 $132.21
Table 7 – Total Monthly Impacts for Lower Volume Single Family Customer, January and July
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January – 2,000 Gallons 2018 Status Quo 2018 Alt.
Water $18.64 $18.56
Wastewater $15.58 $21.18
Stormwater $16.33 $15.61
Total $50.55 $55.35
July – 14,000 Gallons 2018 Status Quo 2018 Alt.
Water $56.50 $56.84
Wastewater $15.58 $21.18
Stormwater $16.33 $15.61
Total $88.41 $93.63
In the MFR class, customers will likely see a small decrease due to the shift in the
wastewater bill from variable use charge to fixed service charge. Those MFR customers
with a relatively high amount of impervious area will see an increase in stormwater/flood
management fees. Tables 8 and 9 show two example multi-family customers, one with 18
units and another with 75 units.
Table 8 – Average Monthly Impacts for Multi-Family Customer
Apartment Complex
(18 Units) 2018 Status Quo 2018 Alt.
Water $830 $820
Wastewater $350 $310
Stormwater $70 $80
Total $1,250 $1,210
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Table 9 – Average Monthly Impacts for Multi-Family Customer
Apartment Complex
(75 Units) 2018 Status Quo 2018 Alt.
Water $3,900 $3,900
Wastewater $1,600 $1,500
Stormwater $380 $390
Total $5,880 $5,790
In the CII class, impacts are more difficult to generalize, as the customers are more
diverse in their attributes and water and wastewater usage patterns. Generally, the
following impacts will result from the changes, if enacted:
CII AMU customers with budgets that were previously set far below their normal
use will experience a decrease in water charges.
CII AMU customers with budgets that were previously set far above their normal
use will experience an increase in water charges.
CII customers will generally see a decrease on their wastewater charge as a higher
proportion of revenues is recovered from the fixed service charge relative to the
volume charge.
CII customers with large amounts of impervious area, including both buildings
and parking lots, will see an increase in stormwater/flood management fees.
CII AMU customers with both previously generous budgets and large amounts of
impervious area will see larger increases in their total utility bill each month due
to increases in the water and stormwater/flood management charges. Some of
these customers will be better served by moving to the Historical Monthly Usage
water budget category and/or conducting a water audit to see if there are any
opportunities for increased efficiency and lower water charges. This category of
customers, those substantially impacted in two utilities, are candidates for targeted
outreach by staff.
CII AMU customers with previously low budgets relative to use and with large
lots but little impervious area will benefit substantially from reductions in both
their water and stormwater/flood management charges.
NEXT STEPS
City staff is seeking feedback from council on the rate structure changes recommended
by WRAB. These changes will then be incorporated into the 2018 budget process where
utility rates are anticipated to be adopted in October 2017.
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