Read response by Bruce Aylward, Ph.D. and Mike Tripp, M.D.
At the request of the Cascade Business News, Allan Bruckner, former mayor of Bend compiled a summary of many of the issues raised by critics of the City of Bend’s Surface Water Improvement Project (SWIP). The article, entitled Contentious. Confusing. Controversial. Trying to Make Sense of a Complicated Issue was published in the January 30, 2012 edition of the paper (click here to download). Subsequently, Tom Hickmann, city engineer/assistant public works director, submitted a multi-component response to the article which was posted on-line (click here to download). Asked to trim the piece for publication Hickmann subsequently submitted a shortened version of his responses including a few changes to his responses (click here to download).
The following perspectives address selected portions of the italicized Hickmann responses and are organized by major topic as raised by Bruckner and responded to by Hickmann. The topics and the order in which they are presented here are:
1. CITY OF BEND WATER USE
1.1 Peak Summer Use (maximum daily demand)
1.2 The City’s Annual Average Diversions
1.3 Water Demand Forecasts
2. WATER UTILITY SYSTEM CAPACITY AND RELIABILITY
2.1 Groundwater Well Capacity
2.2 Reliability of Wells
2.3 The City’s Ability to go to a Groundwater Only System
3. AVAILABILITY OF CITY OF BEND TUMALO CREEK WATER RIGHTS
3.1 Winter Month Demand and Supply
3.2 Summer Months Supply and Demand
4. CITY WATER USE AND TUMALO CREEK
4.1 City’s Impact on Tumalo Creek
4.2 Restoration of Tumalo Creek flows
5. FINANCIAL COMPARISON OF SWIP WITH AN ALL-WELL WATER ALTERNATIVE
6. DESCHUTES GROUNDWATER MITIGATION PROGRAM
7. FIRE RISK IN TUMALO WATERSHED AND WATER TREATMENT
8. ADDITIONAL COMMENTS
8.1 What Other Cities are Doing for Water Supply
8.2 Surface Water Source Stability
8.3 Status of the Old Pipes
Please note that in order to correctly attribute Mr. Hickmann’s comments they are referenced in brackets after each quote with the response version (A or B) and the number of the response, in order of their listing in Mr. Hickmann’s submission.
- 1. CITY OF BEND WATER USE
1.1 Peak Summer Use (maximum daily demand)
Mr. Hickmann makes the following statement about the City’s water use:
The City has recorded peak summer use (maximum daily demand) exceeding 29 mgd in 2009 {A-1, B-6}
Comment: Mr. Hickmann has his facts wrong and his comment is misleading. The 29 mgd (million gallons per day) maximum daily demand figure was reached in 2008 not 2009 (see Exhibit 2-3 of the City’s June 2011 Water Management and Conservation Plan). The figure below provides a graphic depiction of maximum daily demand data for the last nine years, based on data provided by the City. The 29 mgd figure cited by Mr. Hickmann is the highest level recorded by the City. In each of the three summers since 2008, demand has dropped off dramatically. In 2011 a new low of approximately 22 mgd was recorded. It is unclear why Mr. Hickmann feels compelled to cite and rely on old data in responding to Mr. Bruckner’s up to date figures. Mr. Hickmann and his consultants continue to rely on outdated maximum day demand figures and water use growth rates in their forecasts. These 2006 forecasts were used in the 2007 Water Master Plan. Bend is now 6 years down the road, its citizens are enduring a severe economic downturn, and water rates have been rising at 6% year over the last decade. It is not surprising that water use by Bend ratepayers is falling. That the City continues to refer to old statistics and employ such in its planning documents seriously weakens the credibility of its conclusions.
1.2 The City’s Annual Average Diversions
Regarding its future diversions Mr. Hickmann makes the statement that:
The City currently plans to operate the new system within an annual average diversion of up to 21 cubic feet per second (cfs) {A-17, B-7}
Comment: As noted in more detail below the City may eventually, at some time far in the future, fully utilize the new pipe capacity of 13.6 mgd (million gallons per day) or 21 cfs (cubic feet per second). In particular the City anticipates realizing this diversion level during the winter months. To do so it will have to resolve the turbidity issues with the creek water that has caused the City to take the surface water system off-line almost 20% of the time over the last five years. Also, as the City acknowledges in its 2011 Water Conservation and Management Plan (page 2-32) and as discussed further below, the seniority of its water rights precludes it reaching 13.6 mgd during the summer months. Thus, Mr Hickmann is incorrect to imply that the City may reach an annual average diversion of this magnitude. Nevertheless, it is clear that the City does intend to greatly increase its use of surface water once the SWIP is in place. In 2010 the City’s annual average diversion of surface water was just under 6 mgd. So, taking Mr. Hickmann’s statement as an objective, it appears that the City hopes to take 134% more water out of Tumalo Creek once the SWIP is built.
1.3 Water Demand Forecasts
With respect to the issue of forecasting future City water demand Mr. Hickmann states:
The water forecast used the City’s state-approved Deschutes County Coordinated population forecast as required by law, as well as the Buildable Lands Inventory consistent with the existing service area to complete the water demand forecast. {A-9}
Comment: How can the City expect its arguments to be accepted as credible when they continue to use outdated information and unrealistic projections?
Economic recession and population reductions have made projections based on pre-2008 growth obsolete. The Bend Metropolitan Planning Organization in 2007 projected Bend’s population to be 119,000 in 2030. This may be overly optimistic given the recession which continues since 2008, but this ~50% increase is remarkably lower than the ~ 300% increase in City water demand projected in the 2011 Optimatics report and in other City documents. By contrast, Bend’s population is now declining; many feel that pre-2008 rapid growth will not be resumed for decades
This is a fundamental issue not only for firm supply capacity and expansion of capacity debates, but also for the economic analysis of hydropower and for projections of future water user rate increases.
- 2. WATER UTILITY SYSTEM CAPACITY AND RELIABILITY
Mr. Hickmann’s discussion of supply capacity, demand, storage capacities and well reliability is a confusing mix of topics that obscures important perspectives on the Bend’s water utility system. The following comments are directed towards clarifying the points raised. Hickmann’s responses if accurate raise serious questions as to whether the existing water utility, as well as the proposed SWIP plans, meets reliability standards.
2.1 Groundwater Well Capacity
Mr. Hickmann starts out by making an odd statement about the system’s groundwater capacity:
The City’s water master plan, developed by the engineering firm Optimatics, identified the reliable capacity of the City’s groundwater production facilities to be 9.0 MGD (Appendix E, Table 3, page 7). {A-1, B-6}
Comment: The water utility’s supply capacity should be differentiated from storage capacities. The Optimatics Appendix E analyzes use of well water sources “to be considered equivalent to gravity storage” (Appendix E, pp. 6-8); Table 3 details the calculation of the 9 mgd in wells that can be used as storage equivalents. Mr. Hickman’s response uses the “reliable supply” of 9 mgd in well capacity storage equivalence out of context, confusing the storage capacities analysis with the “firm” supply capacity of Bend’s water utility. Optimatics analyzes supply capacities in depth in multiple other sections of the 2011 report; well supply capacity is tabulated at 33.3 mgd, with a total of 32.2 mgd in service as of 2010 (Table 2.2, page 14 of Optimatics Final Master Plan Update).
If the City water utility has only 9 mgd of reliable well and surface water capacity is limited to a “firm planning” capacity of 7.4 mgd (Water Conservation and Management Plan, 2011), how is the City to provide a reliable supply to a city with a maximum daily demand of from 22 to 28 mgd (as detailed in Section 1)?
2.2 Reliability of Wells
Mr. Hickmann then goes on to acknowledge that the City has quite a lot of wells:
The City currently has 20 operational wells at nine well sites, with a total installed pump capacity (which assumes all pumps are operational) of 30.5 mgd. However, the City cannot rely on all of this capacity from groundwater since well machinery has been known to fail without warning. …All of these aspects must be considered when evaluating the reliability or likelihood that a given number of wells will be operating at any given time. {A-1, B-6}
Comment. SWIP will not eliminate the need to correct these deficiencies or avoid this cost. Correcting well infrastructure deficiencies is not a cost of switching to a ground water only system. It is a cost of correcting deficiencies in the existing water utility so as to meet the “firm” supply capacity standard for municipal water systems. If the City’s priority is truly to provide reliable, safe water, as so often stated, the City should already have prioritized correction of well infrastructure deficiencies.
2.3 The City’s Ability to go to a Groundwater Only System
On the topic of the sufficiency of the City’s wells to meet the City’s needs – absent surface water – Mr. Hickmann goes on to make his feeling explicit:
The City does not currently have sufficient groundwater production facilities to reliably meet Bend’s water demand with only groundwater sources…{A-16}
The City would only be able to meet its peak water demand with groundwater exclusively if all of its wells remained operational and peak demand decreased. {A-2, B-6}
Comment. Mr. Hickmann uses questions about the reliability of wells along with misleading demand projections to infer that groundwater capacity is insufficient to meet demand. However, reliability, as distinguished from firm supply capacity, needs to be assured whether Bend has a dual source or a groundwater only water utility.
Engineering standards require water utility infrastructure to meet the “firm” supply capacity standard for municipal water systems. Optimatics emphasizes this in many places in the 2011 report, essentially repeating with slight variation the following:
“Firm supply capacity is defined as the sum of all available (in service) supply sources, minus the largest single supply source. In the case of the Bend system, the largest supply source is, and will continue to be, the surface water source“ {emphasis added}
….From a supply security point of view, however, it is necessary to also consider the system’s groundwater capacity to ensure sufficient supply in the event that the surface water source is not available” (Optimatics 2011; Appendix E, p.1)
Therefore, Optimatics makes it clear that groundwater reliability questions must be addressed even if Bend continues to use a dual-source system. In point of fact, the current City delivery system is often turned off during high flow conditions in the creek due to excess turbidity in the water. If the City’s wells cannot meet demand reliability on their own then the utility will fail to meet demand. Reliability of the wells should therefore be assured.
When considering a groundwater-only system, the firm supply capacity standard requires redundancy in well capacity relative to demand. By the standard used by the City of Redmond in its 2008 Public Facilities Plan and also in the HDR Technical Memorandum to the City of Bend (Surface Water/Ground Water Cost Comparison, October 2010) firm well supply capacity equals total well capacity minus the largest single well. A much more conservative and arguably safer metric for Bend might be that used by the State of Washington: the total well capacity should be enough to provide the maximum daily demand in 18 hours or less of pumping (WA Water System Design Manual, 2009). Effectively this calls for having 4/3s of maximum daily demand in reliable well capacity.
Now consider that in 2011 Bend’s maximum daily demand was 22 mgd. The largest well the City has is the River Well #2 at 3.0 mgd capacity. The approach to firm supply capacity based on the largest well metric would call for maintaining a well capacity of 25.0 mgd. The more demanding Washington standard would call for well capacity of 29.3 mgd. Given current well capacity of 32.2 mgd, one can conclude that current well capacity meets the firm supply capacity standard even by the more stringent Washington standards. The redundancy margin will be even larger when the Outback well #8, under construction in the summer of 2011, is commissioned. In the future, additional new wells will be needed under a groundwater-only system. But this is also true even if SWIP is completed. New wells are required in order to continue meeting the redundancy standard set by Optimatics (as is detailed in multiple sections of the 2011 Optimatics report).
In sum, reliability, as distinguished from firm supply capacity, needs to be assured whether Bend has a dual source or a groundwater only water utility. Due to the rapid drop in water demand in the last few years, and the continued expansion of the well system, Bend’s well capacity currently meets firm supply capacity standards for a groundwater only utility. The City could convert to a groundwater-only system immediately. That Mr. Hickmann does not agree with this point – as made by Mr. Bruckner – suggests that he is offering a novel interpretation of his own consulting reports.
- 3. AVAILABILITY OF CITY OF BEND TUMALO CREEK WATER RIGHTS
3.1 Winter Month Demand and Supply
Regarding the City’s future use of water Mr. Hickmann says the following:
…for six to seven months of the year the City will be able to meet 100 percent of its demand from the surface water supply in twenty years {A-14}
Comment: The City estimates that water use demand will approach 13.6 mgd (or 21 cubic feet per second or cfs) by 2030 (Table 30 of HDR Hydropower Report of 8/5/2011). Winter month demand in recent years has varied between 5 and 6 mgd. The new pipe capacity with the SWIP will be 13.6 mgd. Mr. Hickmann’s comments reflect a belief that demand will almost triple in the next 20 years. This assumption is convenient as it means that the hydropower revenues also grow rapidly.
Outside the irrigation season, which runs from April 1 to October 31st, there is a five-month period during which the City competes for stream flow in the creek only with the instream water right that is held by the State and was filed by Oregon Department of Fish and Wildlife. The target flows for fish and wildlife in the creek are reflected in this junior instream right, with priority date of 1990 (the target flows are shown in the table below.
Instream Water Rights (cfs) in Tumalo Creek (Certificate 73222)
As the City’s winter water rights are senior to the instream right, the City effectively has access to its full legal rights at this time. The City’s water rights during this period total 13.6 mgd (or 21 cfs). The figure below charts stream flow statistics for the creek, demonstrating that there is enough water in Tumalo Creek during winter months for the City to divert its water rights into the pipe. For the five non-irrigation months (not the six to seven months quoted) the City has the rights and water is available so that the City could meet 100% of its projected demand for 2030 of 21 cfs from Tumalo Creek.
However, at present the City does not currently meet its winter need, which averages around 6 mgd, from its surface water system. Storms in the watershed create turbid flows that the City does not want in their system. As a result, when these events occur, the City does not take any surface water into its system at Outback. As shown below, over the last five years the City has, on average, had to avoid taking surface water 62 days a year. The majority of these days are during the winter or early spring months. The City has suggested that the membrane treatment facility will eliminate these shutdowns. This would not be the case if the City went with the less expensive UV (ultraviolet) treatment system.
Down-Time for the City of Bend’s Surface Water System, 2006-2010
The City may also be able to meet a portion of this future demand during April and October but that will depend on flows in the creek and the extent to which irrigators in Tumalo Irrigation District call on their water. In April the creek is more than fully allocated as irrigators call on their water and snow melt is yet to begin in earnest. In October flows remain low and so the ability to meet City water rights depends on when irrigators turn off their water for the season. Much also depends on when City water users turn on their irrigation water. This issue is more fully described in the next sub-section.
Thus, it might be more appropriate to suggest that the City may be able to meet a large proportion of its future winter demands for 5 to 6 months. The turbidity of the creek and the junior nature of the City’s irrigation season water rights suggest Mr. Hickmann may wish to limit his enthusiasm in this matter.
3.2 Summer Months Supply and Demand
Regarding its use of surface water, particularly during the summer, Mr. Hickmann states:
“The City uses surface water as its primary source …. Surface water is supplemented with groundwater to meet peak summer demands {A-1, B-6}
Distribution of water rights by seniority occurs when flows are low to help protect the creek. When the City is placed under distribution, this is typically for less than two months of the year when this does occur. This is not a frequent and long term event which would make the surface water supply less reliable. {A-15}
Comment. Mr. Hickmann provides no evidence to support his assertion that “typically” this distribution occurs “less than two months” a year. The 2009 Brown and Caldwell report that assessed alternatives included a section on water rights and the 2011 Water Conservation and Management Plan also contains a comprehensive review of these issues. Neither of these documents provides further evidence on the frequency of distribution, aside from a few general quotes from the local watermaster. What is provided in these documents is somewhat akin to the figure provided below, that is a mapping of the water rights against water availability in the creek. The figure shows that when stacked one on top of each other by their rate of diversion (in cfs) the water rights on Tumalo Creek exceed even median flow during the snow melt period and vastly exceed available flow for the remainder of the irrigation season. This over-allocation of streams in the western U.S. is a frequent occurrence.
Notes: The graph shows all water rights as compiled from the City’s 2011 Water Conservation and Management Plan and various permits and certificates. The hydrograph is based on data from OWRD for the thirty-year period from 1957 to 1986 (after which the gage was decommissioned). Note that the City of Bend owns the senior right and the 1983 right, as well as portions of the 1900, 1905, 1907 and 1913 rights. It is worth noting that the 1900 to 1907 rights are volume limited, the rates shown can only be used for 60 days before the assigned volume of water is consumed. Thus, this chart does not express the full complexity of assessing water availability in Tumalo Creek.
In the admittedly very technical discussion box provided below an argument is made that the City has, in the past, often failed to use as much of their water rights during the irrigation season as would have been expected. The inference, easily made, is that due to the junior nature of the City’s irrigation season water rights, the City may have to forego using a significant portion of its water rights for a large portion of the irrigation season. This finding suggests, that in planning for SWIP, the City has over-estimated its water right availability. This unduly pushes more costs on to the groundwater only alternative and overstates the revenues from hydropower when comparing SWIP to alternatives.
Discussion Box on Regulation of City Water Rights during the Irrigation Season
When it comes to assessing water availability additional factors that complicate regulation (or distribution) of water rights include physical constraints of the delivery system and the end-use, as well as behavioral factors. An irrigator may have a right to use water but choose not to use that right, for instance. Thus, in assessing the reliability of water rights it is always useful to rely on observed data. Theoretical projections are only of so much value.
With the City’s consultants unable to unearth comprehensive records of regulation by the watermaster, a different approach is put forward here. The City’s level of demand, its physical capacity (at present 11.6 mgd) and its withdrawal of surface water (and pumping of groundwater) can be used to tackle this issue. As Mr. Hickmann indicates the City prefers to take surface water over groundwater, subject to availability. It therefore seems logical that when surface water is available it will be used first to fill City demand. The daily data on surface water and groundwater use obtained from the City can therefore be used to test this hypothesis. If the City is not maximizing its use of surface water it can then be inferred that it is subject to regulation.
Daily observations for 2003-2010 were used to calculate a crude “regulation index.” It is crude because the data reveal that there are very few days, even in winter, when the City actually turns off all of its groundwater wells. Over the last five years, for example, the City pumped groundwater 362 days a year on average. Thus, it is necessary to insert an allowance for some minimal groundwater pumping into the analysis; otherwise it would appear that the City’s water rights are always regulated. As this allowance is increased the days on which it can be said that the City is not maximizing surface water use (due to regulation) decreases. For the purposes of this analysis a 1 mgd allowance is used.
Two examples illustrate the method. On June 3rd, 2007 the City used 21.7 mgd, of which 5.8 mgd came from surface water and 15.9 mgd came from groundwater. The index counts this as a day in which surface water is regulated since the City was taking 5.8 mgd, which is less than their maximum pipe capacity of 11.6 mgd, less 1 mgd for an allowance factor. On that day, as any other the City was taking 11.6 mgd into its pipe at the intake on Bridge Creek and returning 5.8 mg (11.6 mgd less 5.8 mgd) to Tumalo Creek. Presumably this water was being released to satisfy senior water rights at the Tumalo Irrigation Diversion or senior instream rights (created through canal piping or water leasing). On September 9, 2007 the City used 23.7 mgd, of which 11.0 mgd cam from surface water and 12.7 mgd came from groundwater. The index does not count this as a regulation day since the surface water use exceeds the maximum capacity of 11.6 mgd less the 1 mgd allowance.
The table below suggests that the City’s rights are quite frequently regulated. With a 1 mgd allowance they are regulated every day in July for the nine-year period for which data was available. More significantly, the rights were heavily regulated from June through to October (over 90% of the time). Water rights in this example are regulated 79% of the time. Even if the allowance is increased to 2 mgd the irrigation season regulation index falls only to 67%. In other words 67% of the time during the irrigation season the City is more than 2 mgd short of the amount of surface water it would ideally take in order to satisfy City demand, and that it has the legal right and the physical capacity to divert. This suggests that Mr. Hickmann’s optimism regarding how much water the City will be able to convey through its new pipe under SWIP may be vastly overstated. It also bears heavily on the likelihood of generating the forecast hydropower revenues.
Percent of Days that City’s Water Rights are Regulated, 2003-2010
- 4. CITY WATER USE AND TUMALO CREEK
4.1 City’s Impact on Tumalo Creek
Mr. Hickmann goes on to discuss the impact of the City’s diversion on Tumalo Creek, as follows:
The hydroelectric facility, if built, would not take additional water from Tumalo Creek. The facility would generate renewable energy from water that the City uses to meet municipal water demand {A-17, B-7}
Comment: The statement by Mr. Hickmann is misleading. As confirmed above the SWIP (including the hydropower facility) will take additional water from Tumalo Creek, particularly in the winter months. Median stream flow in the creek during winter months is in the mid-60s (cfs). According to its projections, the City will be diverting 21 cfs or fully one-third of the water in the creek by 2030. Measured at the location where the City currently returns unwanted flow from its pipes to Tumalo Creek (near Outback), the SWIP will increase the City’s current take of water during the winter months from 8.5 cfs (5.5 mgd) to 21 cfs or a 150% increase over current diversions. The City has carefully avoided drawing public attention to this awkward consequence of their plans, nor accounted for the environmental impacts of these additional diversions in any of their documentation about the project.
Mr. Hickman goes on to try and make the case that the SWIP should be evaluated only on the basis of the increase in diversion:
With the new system, the City will only divert more than 18.2 cfs (current allowed diversion) when there is a municipal demand for it, and the water is available. Availability is based on water rights and available flow. So, the net increase of withdrawal of water from Tumalo Creek (when the water is available and City demand would require it) is 21.0-18.2 = 2.8 cfs. This is a maximum increase of 15 percent. {A-17, B-7}
Comment. This is inconsistent with Mr. Hickmann’s statement that no “additional” water is to be diverted.
The main point here however is that Mr. Hickmann seems concerned only with the increase in water use and thereby misses the obvious point that under a well only water supply system the City would divert 0 (zero) water from Tumalo Creek. Because the SWIP involves fully rebuilding the City’s pipes that bring the water into town the SWIP should be (and was) compared to other alternatives that do not involve rebuilding the City’s surface water diversion and conveyance system. The “with and without” SWIP comparison then would be between 21 cfs in diversions and 0 cfs of water diverted. Mr. Hickmann seems unaware of common practice and methods in project analysis, in particular how to structure an alternatives analysis and evaluation their impacts on water resources.
4.2 Restoration of Tumalo Creek flows
With respect to Tumalo Creek flows Mr. Hickmann recognizes the stream flow issue with the following statement:
Tumalo Irrigation District, who owns large senior water rights on Tumalo Creek, have identified over 30,000 acre feet of losses and are actively conserving the 50 percent leakage within their canal system. Additional options exist to prioritize flows that meet all the needs of fish, farms, and people and the City of Bend is actively working with all basin groups to achieve these goals. {A-15}
Comment. Once again, the City has put forward an argument that lacks credible objective support.
An informative response to recent inquiries on this issue was received from the Deschutes River Conservancy. This was summarized in detail for Trout Unlimited and StoptheDrain (click here to download). The City argues that in stream flows are best met through programs based on Tumalo Irrigation District conservation programs. However to complete proposed TID conservation plans major public financing will be required, and unfortunately the resultant flow restoration will still fall far short of the Oregon Fish and Wildlife flow goal of in-stream rights of 32 cfs. “All the needs of fish…” will not be met under the City’s proposal.
- 5. FINANCIAL COMPARISON OF SWIP WITH AN ALL-WELL WATER ALTERNATIVE
Mr. Hickmann makes the following statement about the financial comparison of SWIP and Groundwater Only alternatives:
The cost of power required to run well pumps is expected to exceed the City’s interest payments over the course of the City’s loan for the Surface Water Improvement Project. On a present value basis, it is cheaper to pay interest on the loan to invest in energy-efficient surface water than it is to pay long term, escalating power bills for groundwater {A-19, B-10}
Comment: Mr. Hickmann is an engineer not a financier or an economist. For these figures Mr. Hickmann is relying on the HDR comparison of SWIP and the Groundwater Only alternative (dated October 2010). The HDR study has already been rejected as illegitimate on two accounts.
First, as pointed out by Mr. Bruckner in his CBN piece there was a huge conflict of interest in “hiring” HDR to conduct such an analysis in the first place. Had HDR found in favor of the Groundwater Only alternative they stood to lose their already approved, large $13 million contract to provide engineering services on the SWIP. Mr. Hickmann has never owned up to this criticism of his performance and has never even acknowledged that this was a conflict. Further, Mr. Hickmann never sought any independent validation of the HDR study, even when provided with an initial critique of the study in November of 2010. Instead, Mr. Hickmann continues to trot out tired and discredited statements of this kind.
Mr. Hickmann’s figures for costs of power to run pumps depend completely on unrealistic growth rates in water use and the increase in power costs. In a private meeting held between the City and the opposition, even the City’s consultants agreed that the 6.2 per year increase in power costs projected was excessive. A new financial and economic model created to compare the SWIP and Groundwater Only alternatives by recalculates the figures cited by Mr. Hickmann, as described below.
The cost to pump groundwater (to replace surface water) should the City move to all groundwater is just over $610,000 per year. The costs of interest on the $69 million will depend on the rates obtained by the City. A blend of market and federally-subsidized rates might average about 4.5% or about $3 million a year. In addition, Mr. Hickmann seems to have forgotten that the loans also need to be paid back by the City. So Mr. Hickmann is flat out wrong to say that the present value of the pumping costs will exceed the interest payments. In the Aylward model present value of interest payments exceeds pumping costs by more than 2 to 1. In fact, over the 50-year planning horizon the net present value of all the pumping required for all 50 years is less than $20 million (with a 1% growth rate and a 3.3% increase in power costs).
In point of fact Mr. Hickmann’s argument is irrelevant. For at least the last 50 years it has been generally accepted that the way to judge between project alternatives is on the net present value of all costs and benefits involved . . . not just pumping costs or interest costs. On these grounds, the model developed by Aylward suggests that a groundwater-only alternative is less costly than SWIP in financial terms by between $30 to $40 million. This is before ascribing any value to the benefits that would be realized by the City placing its water rights instream for fish, wildlife, water quality and recreational purposes. This would mean from 2 billion (now) to 4.5 billion gallons (at end of 50 years) of additional cold water in Tumalo Creek. This could represent an additional $10 million in savings to the public. So in a direct comparison of SWIP with a groundwater-only alternative the groundwater-only alternative comes out as the superior choice by some $40-$50 million.
Mr. Hickmann has been peddling the idea that pumping groundwater is horribly expensive for some time. Its time he stopped citing discredited numbers.
- 6. DESCHUTES GROUNDWATER MITIGATION PROGRAM
Mr. Hickmann has this to say about the Deschutes Groundwater Mitigation Program:
the Oregon Deschutes Basin Groundwater Mitigation Program limits additional groundwater use and remains controversial {A-3, B-2}
Comment. The Groundwater Program limits additional groundwater use in order to protect flows in the Lower Deschutes, a State Wild and Scenic Waterway. New groundwater permits are issued only once the flow impacts of the new use are offset by mitigation projects approved by the Oregon Water Resources Department.
The Program began with rules issued by OWRD in 2002. The program was challenged by Waterwatch of Oregon, which succeeded in arguing that the program should offset impacts rather than merely mitigate (or reduce) these impacts. Basin stakeholders then went to the legislature which in 2005, which put the Groundwater Mitigation Program into statute in a matter of months. HB 3494, which authorized the Program through a 2014 sunset, was carried 53-5 in the House and 27-1 in the Senate. It was signed by the Governor on July 29, 2005.
In 2011, three years in advance of the sunset date, basin stakeholders decided to convince legislators to extend the sunset of the Program, given general concurrence by OWRD and stakeholders that the program was successful. HB 3623 of the 2011 session extended the sunset of the Oregon Deschutes Basin Groundwater Mitigation Program from 2014 to 2029, a fifteen-year extension. The bill passed the Oregon House with a 59-1 vote. It passed the Oregon Senate unopposed. The Governor signed the bill on August 2, 2011.
The Program was controversial in 2002 when the City of Bend was fighting imposition of the Program and when Waterwatch was arguing the Program was not comprehensive enough. It is no longer controversial. Patrick Griffiths the City of Bend’s Water Resource Coordinator appeared at hearings on HB 3623 extolling the benefits and importance of the Program. Mr. Hickmann is either out of touch with developments in the basin over the last five years or is attempting to mislead Council and ratepayers about a Program that is cited across the Western United States as an important example for how water should be managed more productively for both human and ecosystem uses.
Furthermore Bend’s secure groundwater rights will arguably ccommodate, with modest conservation programs, growth to 140,000 residents, taking into account Avion and Roats service populations. Forecasting beyond this limit conjures up many scenarios; who can predict the future that far ahead? Planning now should focus on maximizing flexibility while minimizing risk so as to allow optimal adaptation to evolving circumstances and unpredictable events. The surface water project does the opposite. It minimizes flexibility while maximizing risk given its all or none, immediate and irreversible investment profile.
On a related point Mr. Hickmann also states:
The United States Geological Survey has evaluated the environmental impact of Bend relying solely on groundwater . . . If the City uses more groundwater, it is projected to deplete flows in the Deschutes River upstream from Bend, Tumalo Creek, Whychus Creek, the Crooked River, Alder Springs and other springs. By maintaining both its surface water and groundwater sources, the City can manage the potential environmental impacts of its water supply [A-18, B-8}
Comment. Mr. Hickmann continues to make misleading and incorrect inferences (in this case about other peoples’ work). USGS did not in any way examine what would happen if Bend relied solely on groundwater. USGS was rather examining the impacts of pumping groundwater in the Bend area and used the City as an example. As indicated above the only reason there is a Deschutes Groundwater Mitigation Program is to address the potential for groundwater pumping to deplete stream flow. The City, along with all other new permit holders, is providing mitigation for its new pumping rights. This mitigation effectively offsets the potential impact that pumping would have on the Lower Deschutes.
Here again, Mr. Hickmann statements are hard to reconcile with other information. To state that the City can “manage” the impact on the environment of its water supply by using both surface water and groundwater is an unsubstantiated assertion. The State has already seen fit to protect the Lower Deschutes from additional groundwater pumping by the City. Were this not the case the City would likely not be doing anything to “manage” this environmental impact. However, the State can do nothing about the City’s continued and increasing diversion of water from Tumalo Creek a stream that is effectively dewatered by the combined impact of City of Bend and Tumalo Irrigation District diversions. This is the environmental impact that remains unaccounted for by the City and is not addressed in any of its SWIP planning documents. The use of water from Tumalo Creek has much more devastating impacts on fish and wildlife than does groundwater pumping, that is anyway offset through mitigation projects paid for by the City.
- 7. FIRE RISK IN TUMALO WATERSHED AND WATER TREATMENT
An important risk for the City’s surface water system is the risk of fire in the Tumalo Watershed. On this topic Mr. Hickmann has this to say:
Primarily, however, the filtration treatment method was selected as the best available technology to allow the City continued use of the surface water in the event of a fire in the watershed that contains a significant portion of dead trees as a result of beetle kill. {A-11, B-5}
Comments: Mr. Hickmann’s comments here, and on prior occasions, regarding the City’s plans for managing watershed fire risks contain inherent contradictions and reveal deficiencies in SWIP cost estimates.
Fire in the watershed is a major risk for the City’s surface water system. According to the US Forest Service this is an issue of when such a fire will occur and not if one will occur. Given this, the value engineering team commissioned by the City recommended completion of a system which would in fact be prepared to operate in the event of a forest fire in the watershed (Final Value Engineering Study report, March, 2011). The Public Works department rejected this recommendation, arguing that the City could operate on ground water only for the minimum of 3 to 4 months required for equipment procurement, (installation time not estimated) if a fire occurred (VE report, Appendix J, Item T-53). This seems inconsistent with the City’s argument regarding unreliability of the well system (addressed in Section 2 above)
In spite of all the rhetoric, the proposed membrane treatment plant, under the current SWIP proposal, will not be equipped with the rapid mix, flocculation, sedimentation planes, sludge pumps and possibly activated charcoal filtration systems the membrane plant will require to treat water after a watershed fire. Cost inquiries to the City on this question were made earlier in 2011. The City responded that no cost estimates were available. In the fall of 2011 Mr. Hickmann stated at a meeting that equipment for fire consequences would entail a capital investment of greater than $3 million, but offered no comment on operating and maintenance expense increases that would follow; these in all likelihood will be substantial. One can conclude that expense estimates for the City’s commitment to a membrane treatment plant lack credibility.
Furthermore the fire scenario planning comes back to the water supply issue discussed above. If the City proposes to be able to operate for many months on ground water only while the treatment plant is upgraded after fire in the watershed, the ground water system surely must meet reliability and firm supply standards. Yet Mr. Hickmann argues that currently our well infrastructure does not have adequate reliable capacity to operate without surface water supplementation. He can’t have it both ways.
On top of this, the City has now proposed that if the EPA grants an LT2 rule compliance delay, the City could install the new pipe without a treatment plant. Again this can only be a rational plan if in fact well water infrastructure is sufficiently reliable to meet capacity demand after a fire.
- 8. ADDITIONAL COMMENTS
8.1 What Other Cities are Doing for Water Supply
Mr. Hickmann uses cities in the valley or on the coast as reference points, as follows:
Many cities in Oregon use a dual-source system and/or use surface water for their water supplies. Many more are seeking new surface water supplies. Some of these cities include Portland, Albany, Wilsonville, Hillsboro, Beaverton, Pendleton, Tualatin, Lake Oswego, Tigard, Salem, Corvallis, Clackamas, Lincoln City, Newport, and Medford. Eugene Water and Electric Board (EWEB) and McMinnville are currently working to secure a dual-source water supply. {A-14, B-1}
Comment. While the experiences of other cities are of interest, the circumstances in Central Oregon are different: the quality of the aquifer, the expense of the surface water option relative to the contribution to supply capacity, and the likelihood of slow growth in the near future dictate that analyses should be specific to Bend’s circumstances. Further, Mr. Hickmann omits references to cities closer to home. For example, the cities of Sisters and Redmond are leasing their surface water rights instream and operating groundwater only systems.
8.2 Surface Water Source Stability
Mr. Hickmann has this to say about water from Tumalo Creek:
Bend’s surface water source is supplied by a large and complex spring system that is fed by precipitation from both rain and snow melt. This water source is very stable and dependable and the recharge area is in the protected Deschutes National Forest. {A-15, B-3}
Comment. Climate change is a major variable for planning ahead 50 to 100 years. Surface water proponents contend that the pay-off for SWIP will be realized after 50 years. Climate change scientists have concluded that surface water systems will be affected sooner and more severely than groundwater. A recent study in Central Oregon suggests that tributaries in the upper Deschutes may see a decline of up to 10% in late summer flow due to declining mid-elevation snowpack. Maximizing adaptability over the next 50 or more years minimizes this risk. SWIP does not pass this test.
8.3 Status of the Old Pipes
Mr. Hickmann has this to say about the pipes currently delivering creek water to the City water system:
The two existing pipes are not being replaced simply because of age. There are numerous factors involved that expose both pipes to critical failure and expose the public to health and safety risks. {A-7, B-4}
Comment. Bend should be prepared at any time to operate reliably on groundwater only in the event that surface water failures occur. Thus the “risk” of pipe failure is only significant to the extent that Bend’s water utility fails to provide reliable groundwater capacity. SWIP does not obviate Bend’s responsibility to secure reliable groundwater capacity.
