Roosevelt Water Conservation District ROOSEVELT WATER CONSERVATION DISTRICT



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ROOSEVELT WATER CONSERVATION DISTRICT RESPONSE TO ARIZONA POWER AUTHORITY REQUEST FOR INFORMATION DATED SEPTEMBER 12, 2012 PRESENTED OCTOBER 24, 2012

RWCD is an irrigation district that was established in 1920. Our service area encompasses about 40,000 acres and includes portions of Chandler, Gilbert, Mesa, and unincorporated lands in Maricopa County. Our Main Canal is about 21 miles long; and, our Extension Canal is about 5 miles long. Both canals are fully concrete lined. Our lateral system is made up of about 70 miles of underground concrete pipelines; and, about 25 miles of concrete lined ditches. Our Main Pumping Plant pumps surface water from the SRP South Canal up to the head of the Main Canal. The Main Pumping Plant can pump up to 250 cfs or 10,000 MI. We constructed a 3.5 mile 42-inch underground concrete pipeline that we use to convey CAP water from the CAP Canal to our Main Canal. The CAP Pipeline can deliver up to 130 cfs or 5,200 MI. We use 35 irrigation wells that have the capacity to pump up to 173 cfs or 6,918 MI. All of the groundwater produced from our irrigation wells is discharged directly into our Main Canal and our Extension Canal for delivery to customers by gravity flow. We have two agricultural return flows retention ponds that recapture Tailwater. We have four pumps that pump water from the ponds back into the Extension Canal. We have two lift stations that pump the recaptured water about 3 1/2 miles upstream for redelivery to customers downstream by gravity flow. We are predominately a groundwater based irrigation district. Our water resources are comprised of groundwater, Salt/Verde surface water, SRP San Tan Industrial Effluent, and In-Lieu Water that substitutes for groundwater on a temporary year-to-year basis.

During the 1930 s, RWCD paid the costs to concrete line about 31 miles of SRP s major canals in the East Valley, which were dirt canals. During the 1980 s, RWCD paid the costs to reline the 31 miles of SRP canals. As a result of paying for the costs to concrete line and maintain the approximate 31 miles of SRP s canals, RWCD receives 5.6% of the Salt River and Verde River surface water that SRP diverts at the Granite Reef Diversion Dam. Such water represents surface water that would otherwise have been lost to seepage from the dirt canals if RWCD had not paid to concrete line portions of SRP s canals. The amounts of Salt/Verde surface water that is made available to RWCD varies significantly from year to year based on SRP s operation of their reservoir system, which is impacted by the annual rainfall and snowpack on the watershed. The annual amount of Salt/Verde surface water is reduced by the amounts of such water that were used to settle water rights claims against the District s landowners by five Indian Tribes. The City of Chandler and the Town of Gilbert have domestic water service agreements with RWCD. In accordance with the agreements, Chandler and Gilbert purchase Salt/Verde surface water from us that is delivered to them via the SRP conveyance system. They treat the surface water to drinking water standards and deliver the potable water back to their customers located in the RWCD service area. As a result of weather patterns, SRP operation of the reservoir system, water right settlements obligations, and deliveries to Chandler and Gilbert, RWCD has a limited annual supply of Salt/Verde surface water. For 2013, we project to only have about 4,000 AF of such surface water available to help meet our irrigation demands.

During the early-1990 s, RWCD worked with the Arizona Legislature to enact laws that resulted in the indirect recharging of excess CAP water (In-Lieu Water). RWCD was one of the first irrigation districts to indirectly recharge excess CAP water. The use of excess CAP water by Arizona irrigation districts benefited the State of Arizona by storing excess CAP water that would otherwise have been left in the Colorado River for use by other states. We have also indirectly recharged City of Chandler New Conservation Space (NCS) surface water; and, City of Mesa municipal effluent. Both categories of water are designated as InLieu Water by the Arizona Department of Water Resources. In order to receive In-Lieu Water, RWCD must reduce its groundwater pumping on a gallon-for-gallon basis for each gallon of In-Lieu Water received. Our use of In-Lieu Water on an annual basis is a principal feature of our Integrated Resource Plan. Our use of temporary In-Lieu Water has dramatically reduced our annual groundwater pumping, which would have been much higher if we had not used the In-Lieu Water supplies. The District can and will pump groundwater with Hoover Power if In-Lieu Water is not available. We do not want to be effectively penalized for using renewable InLieu Water by receiving a lower allocation of Hoover Power than we would otherwise have received had we pumped groundwater. We have proposed a simple, yet accurate, method to normalize our historical load data to demonstrate what our electrical loads would have been if we had not used In-Lieu Water.

METHOD TO NORMALIZE RWCD LOADS FOR USE OF IN-LIEU WATER 1. We identified the total water production in acre-feet (AF) for the peak day in June 2012, which was June 21, 2012. The total water production was 473.11 AF. 2. We next subtracted the San Tan Industrial Effluent volume of 10.16 AF to arrive at total net water production of 462.95 AF. 3. We then converted the total net water production of 462.95 AF from acrefeet into Arizona miners inches (MI) using the formula: [AF divided by 1.9835 AF/cfs and then multiplied by 40 MI/cfs]. This calculation resulted in total net water production of 9,336 MI. (1 MI is 1/40th of a cfs.) 4. We then scheduled the amount of our SRP Salt/Verde surface water that could reasonably have been expected to be delivered through our Main Pumping Plant on June 21st. 5. We next dispatched the wells that would have been operated to satisfy the remaining total net water production requirements. We know the order in which we schedule our wells to meet daily water demands. 6. We know the kilowatt demand for each of our electrical loads from SRP. We added up the kilowatt demands for those wells that would have been running on June 21st. We also determined the kilowatt demand that would have resulted from the operation of our Main Pumping Plant on June 21st. The sum of the Main Pumping Plant demand; our irrigation wells demand; and, lift and sump pumps demands resulted in the total kilowatt demand of the District for June 21, 2012. 7. We used the June 2012 SRP wheeling loss factor of 5.18%. 8. We increased the total kilowatt demand calculated in step 6 to reflect the SRP wheeling loss factor from step 7. The result is the District s total kilowatt demand reflected at the District s Hoover Delivery Point. 9. The normalized energy consumed for June 21st was calculated by multiplying the kilowatt demand calculated in Step 8 by 24 hours of operation on June 21st. 10.Our calculations resulted in a total demand and energy of 11,478.45 kw and 275,482.89 kwh, respectively, for June 21, 2012 reflected at the District s Hoover Delivery Point of Pinnacle Peak 230-kV Substation. Our normalized system peak demands are coincident demands by virtue of the method of their determination.

EXISTING RWCD POWER AND WHEELING ARRANGEMENTS 1. Existing Hoover Allocation. (a) 6,760 kw maximum capacity and 23,106 MWh of energy. (Maximum capacity during Summer 2012 was 6,140 kw.) (b) Point of Delivery at Pinnacle Peak 230-kV Substation. 2. Existing Colorado River Storage Project Allocation. (a) Summer CRSP (SHP) Allocation (April September). 1,250 kw maximum capacity and 4,001 MWh of energy. (Our Contract Rate Of Delivery is 2,199 kw.) (b) Winter CRSP (SHP) Allocation (October-March). 1,240 kw maximum capacity and 2,756 MWh of energy. (Our Contract Rate Of Delivery is 1,503 kw.) (c) Point of Delivery at Pinnacle Peak 230-kV Substation. 3. Salt River Project Supplemental Power and Wheeling Service. (a) Supplies supplemental power as needed per contract. (b) Transports RWCD s Hoover and CRSP Resources from our contract Point of Delivery to the individual RWCD loads. (c) Provides hourly resource scheduling and Hoover reserves.

DESIRED RWCD HOOVER POWER ALLOCATION 1. RWCD is only seeking an allocation of Hoover A Power. 2. RWCD is seeking a renewal of its current allocation. We estimate an allocation of 6,827 kw and 21,951 MWh after adjustment for changes in APA s Hoover A Power allocation resulting from the federal legislation. 3. RWCD desires a contract term of 50 years. 4. RWCD requires Hoover A Power on a monthly basis. SRP will schedule the Hoover A Power on an hourly basis. 5. Hoover Point of Delivery at Pinnacle Peak 230-kV Substation. 6. RWCD will use Hoover A Power only for Irrigation Pumping, which is made up of the use of groundwater irrigation wells, operation of the Main Pumping Plant, and lake & lift pumps.

ALTERNATIVE HOOVER POWER ALLOCATION METHODS Exhibit A Alternative Allocation Methods 2 & 5 If these methods are to be considered, then we recommend that: The average of 10 years of load should be based on annual system peak demands on a net load basis. Hoover capacity is predominately used to supply the summer peak demands of applicants. Therefore, an allocation on capacity, rather than energy, would recognize that Hoover is primarily a peaking power plant and reflect how applicants would use the Hoover Power. Annual peak demands should be normalized for In-Lieu Water used by applicants in place of groundwater. Net Load should be determined as each applicant s normalized annual system peak demand less the applicant s CRSP and PDP capacity. However, the federal government has substantially changed the water release patterns at the Glen Canyon Dam. Consequently, Western reduced the CRSP capacity allocations from the level of the Contract Rate Of Delivery (CROD) to the Sustainable Hydro Power (SHP) levels. These lower CRSP SHP capacity allocations should be used to calculate net load rather than the CROD capacity; otherwise, the Hoover Power allocations will be biased against applicants with a CRSP allocation.

ALTERNATIVE HOOVER POWER ALLOCATION METHODS Exhibit A Alternative Allocation Methods 3, 4 & 6 For these three methods, we disagree with granting allocation priority to agricultural loads. Many existing Hoover customers have a variety of electrical loads, which include agricultural and nonagricultural loads. Many Hoover customers have relied and depended on their Hoover Power allocation to serve non-agricultural loads. To reduce their allocation as a result of a bias toward agriculture would likely have negative economic consequences for such customers. While the majority of our irrigation pumping load is agricultural; we also serve urban landscape customers. We treat all of our customers the same; and, they all are charged the same water rate. If the APA chooses to allocate Hoover Power on the basis of agricultural loads, then we will receive a lesser allocation of Hoover Power. Our costs would increase and our water rates would rise to all users. Therefore, our agricultural users would receive a rate increase because Hoover Power was allocated on the basis of agricultural loads, which seems to be the opposite of what the APA is attempting to accomplish.