1. Western Resource Advocates Linda Stitzer [linda.stitzer @ westernresources.org] GUAC Meeting 9/18/2012

2. The large AWS groundwater allowance perpetuates overdraft and the potential for future physical availability problems Recommend the 4MP include a discussion of “legal overdraft” implications and options Consider CAWS revocation if no progress Aquifer augmentation Consider incentives and opportunities for non-recoverable recharge urban stormwater recharge – e.g. multi-purpose flood control non-recoverable effluent recharge (Prescott permit) Low Impact Development - Fort Huachuca parking lot conversion est. 6-8 af/year infiltration

3. In an area of limited alternative supplies, conservation is even more important and should be part of the deficit reduction strategy No regrets approach; often cheaper, faster, few legal issues “Conservation of water supplies is perhaps one of the most simple, yet potentially effective methods to help offset future unmet water demands. It is assumed that conservation in all water use sectors will be an ever-increasing practice in future years, and one capable of generating reductions in future water use for all groundwater basins in the state.” (WRDC Water Supply and Demand Working Group Report, August 1, 2011) Need to do a better job of evaluating and communicating effectiveness and economic benefits

4. Conservation (cont.) Management Plan + aggressive coordinated regional effort Revisit BMPs; consider mandatory programs with measureable savings Current 5 programs ; 2 education and awareness e.g. Prescott BMP landscape conversion success (53 af) w/substantial additional savings possible Exterior potential through efficiency, rainwater harvesting, LID “Hard wired conservation”. Measureable fixture replacement savings – 41 gpcd interior achievable

5. Conservation (cont.) Stricter lost water requirement focused on leak reduction ADWR support for Regional effort Conservation fees? UVRWPC or a non-profit? The Cochise Water Project [ http://www.thecochisewater project.com/] Incentives/BMPs that tie water use to land use policies More rigorous standards in AWS review Conservation Overlay Zone Water demand offsets for new development – e.g. Santa Fe, San Luis Obispo

6. Regional development of meaningful new approaches…that could include legislation, strategic groundwater recharge, dedication of a portion of recharge to the aquifer and a sub-area management program to address environmentally sensitive areas, areas of rapid groundwater decline and other management objectives (aka “enhanced aquifer management”) Consider incentives that focus recharge in areas of most hydrologic benefit Consider an effluent recharge cut to the aquifer that could vary depending on aquifer or environmental benefit Evaluate current effluent incentives that allow higher use rates – effluent is a critical resource Well drilling limits in designated areas Areas of rapid decline/overdraft Environmentally sensitive

7. Incentives and requirements to address groundwater pumping by domestic wells and new industrial users Evaluate unused industrial groundwater rights (1,500 af/yr current; 7,500 af/yr potential) and groundwater permits Consider replenishment obligation, conservation and reuse requirements Extinguishment incentives or fee-supported purchase and retirement program (as per ag) Domestic wells ADWR/community supported conservation program where there is most conservation potential in sensitive areas

8. “Estimated Water Demand and Conservation Potential of Domestic Wells in the Sierra Vista Subwatershed” http://www.westernresourceadvocates.org/water/SVS_ domestic_well_conservation_June.pdf  Focus on older houses near the river

9. If the 4MP is envisioned to be more “a plan” to achieve the safe-yield goal, we support … evaluation and recommendations of what potential actions are needed. Ideally, this would be the starting point for a local/regional cooperative water resource planning process to develop implementable safe-yield strategies. We encourage the Department to initiate this effort and provide support to PrAMA communities.