Loading...
HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 02/14/2017 - CHANGES TO THE UTILITIES RAW WATER REQUIREMENTSDATE: STAFF: February 14, 2017 Donnie Dustin, Water Resources Manager Carol Webb, Water Resources/Treatmnt Opns Mgr Lance Smith, Utilities Strategic Finance Director WORK SESSION ITEM City Council SUBJECT FOR DISCUSSION Changes to the Utilities Raw Water Requirements. EXECUTIVE SUMMARY The purpose of this work session is to seek City Council input on staff’s proposed changes to the current Raw Water Requirement (RWR) system and associated Cash-in-Lieu (CIL) rate. The review of the RWR and CIL has been prompted by various recent events (e.g., change in water use and water right prices) and has resulted in staff proposing several changes to the RWR and CIL that are needed to ensure that the impacts of new development will be offset and that the City will have adequate water supplies and infrastructure. Staff will provide City Council with an overview of the current RWR system and associated CIL rate, which allows for generating adequate funds and water rights to provide a reliable water supply for new development (and redevelopment needing increased water service) within the Utilities water service area. Utilities staff recommends the following changes:  Adjust RWR schedules to reflect recent (lower) water use o Use number of bedrooms for indoor component of residential schedule  Adjust CIL rate per a hybrid cost approach o Increase CIL rate to $16,700 per acre-foot of RWR  Accept cash only (and existing City-issued water certificates and credits) o Discontinue the dedication of water rights  Require periodic adjustment of the RWR and CIL. o Review and adjust (if necessary) the CIL rate biennially o Review and adjust (if necessary) the RWR schedules every 5 to 7 years GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED What feedback does Council have on the proposal to: 1. Change the amount of raw water required? 2. Change the CIL rate and methodology? 3. Accept cash only? 4. Require periodic updates to the RWR and CIL rate? BACKGROUND / DISCUSSION The Raw Water Requirements (RWR) are a dedication of water rights or cash-in-lieu of water rights (CIL) to ensure that adequate water supply and associated infrastructure are available to serve the water needs of development (including redevelopment needing increased water service). Staff will present background information including the existing RWR system and CIL rate, future development and water supply needs, water use changes, and potential changes to the RWR system and CIL rates. February 14, 2017 Page 2 Water Service Areas in Fort Collins The City of Fort Collins Utilities (Utilities) water service area covers the central portion of Fort Collins. As the City continues to grow into the Growth Management Area, much of this growth will be outside the Utilities water service area, and will instead be in the service areas of the surrounding water districts (mostly the East Larimer County Water District and the Fort Collins-Loveland Water District (Districts). Water service for much of this growth will thus be provided by the Districts. The attached map shows these service areas (Attachment 1). Although regional water collaboration discussions are ongoing with the Districts and direction or potential outcomes of those discussions have yet to be determined, any proposed changes to the RWR will only apply to water service from Utilities and within the Utilities water service area. This does not preclude future changes to the RWR for water service from Utilities based on potential outcomes of the regional discussions or from the Districts modifying their respective water dedication requirements. Raw Water Requirements The RWR is a requirement for providing adequate water supply service by Utilities. It currently requires a dedication of water rights, a payment of cash-in-lieu of water rights, or turning over City-issued water certificates to ensure that an adequate supply of raw (untreated) water and associated infrastructure (e.g., storage reservoirs) are available to serve the needs of development (including re-development needing increased water service). Generally, the RWR are based on water use and development type. The current RWR schedules are attached (Attachments 2 and 3). The goal of the RWR is to acquire adequate water rights and funds to provide a reliable raw water supply for a development. Although not the focus of this discussion, other water-related development fees include water and wastewater plant investment fees (PIFs) that are assessed to cover the treatment and distribution infrastructure required to process and transport treated water and resulting wastewater into and out of a development. These water-related development fees are one-time impact fees (or requirements) and are separate from water rates, which recover the operational costs of running and maintaining this infrastructure. For the purposes of this discussion, RWR refers to the volume of raw water needed to meet the projected water use of a development (in acre-feet of water) and the CIL fee refers to the cash equivalent of that water supply needed. The current amount of RWR assessed for residential development is based on a calculation that incorporates indoor and outdoor use components and a water supply factor multiplier. The current amount of RWR assessed for non-residential (or commercial) development is based on the average use for particular meter (or tap) sizes and also includes a water supply factor multiplier. The water supply factor used in both the residential and commercial RWR schedules is currently 1.92, which means that Utilities requires 1.92 times the amount of the projected (or average) water use of a development. Reasons for this factor include the need to account for treatment and distribution losses in the supply system, variable demands of customers (e.g., higher use during hot, dry years), variable yields of supplies (e.g., less yield in droughts) and variable yield from the Utilities different water supply sources (since some yield better than others). Given these and other uncertainties in providing reliable water supplies (e.g., climate change), the 1.92 water supply factor continues to be necessary. Once the amount of RWR for a development is determined (in acre-feet), the RWR currently can be satisfied with acceptable water rights, a payment of cash in-lieu-of water rights, City-issued water certificates or credits, or a combination. The water rights currently accepted by Utilities for satisfaction of the RWR are attached (Attachment 4). The CIL rate is currently $6,500 per acre-foot of RWR. Previous adjustments to the CIL rate have considered the raw water supply situation of Utilities at the time, including factors such as the market price of Colorado-Big Thompson Project (CBT) units, the potential value of local water rights (e.g., Southside Ditches), and the goal to receive an appropriate mix of water rights and cash needed to develop additional firm yield for development. Among other things, changes to the CIL rate should consider the cost to acquire additional storage capacity (e.g., Halligan Water Supply Project) and other facilities required to fully utilize the Utilities water rights portfolio, the value of the existing water supply system, and developing a methodology for easily updating the CIL rate. February 14, 2017 Page 3 Future Development The amount of RWR needed to meet Utilities’ future water supply needs includes calculating the projected amount of future water use, determining the water rights and/or facilities needed to meet that projected use, and adjusting the RWR to acquire the necessary supplies and/or facilities. Calculating the projected amount of future water use and expected RWR that will be turned in depends on projected growth (both population and commercial/industrial). The Utilities’ water service area population is projected to grow about 45,000 by the year 2065 (from the current population of about 133,000 to about 178,000). Based on the current RWR schedules, this projected growth is estimated to provide about 11,900 acre-feet of additional RWR that will be turned in to Utilities. However, water use has significantly changed since the current RWR schedules were developed. Water Use Changes The current RWR schedules are based on a 1983 study focused on relating actual water use with the raw water requirements. The study analyzed annual water consumption data broken into categories based on number of dwelling units, type of living structure, and equivalent lot size (net total area of development divided by number of dwelling units). A linear formula was then derived which could be used to project consumption on the basis of residential density (number of units and size of lot), utilizing the same formula for both single-family and multi- family developments. This projected consumption is the “expected use” for a particular type of development. Acknowledging the impacts of conservation on the City’s water consumption, Utilities staff studied recent water use patterns for single-family, multi-family, and commercial developments. The results of the study showed significantly lower water consumption for single-family and multi-family developments over recent years, as compared to the expected use from the current RWR calculations. Differences in water consumption for commercial developments were not as significant, though changes were also present. The differences in expected use versus recent actual use prompted staff to investigate possible methods for updating the water use formulas in the RWR in order to better project expected use for future developments. Methods To investigate recent trends in water consumption, the past 10 years (2006-2015) of monthly water billing data was analyzed, broken out by single-family residential, multi-family residential, and commercial developments. Utilizing 10 years of consumption data helps to capture climatic variations, which can greatly affect water consumption across all development types. From the outset, the data for different types of residential developments were analyzed separately, with the anticipation that average consumption trends would differ between development types. Further investigation into the use data and types of developments led to combining data for duplexes with single-family developments. Single-family/Duplex Due in great part to successful conservation efforts, water consumption for single-family residential customers has decreased. The current analysis shows a significant difference between the average annual use per single-family home and the calculated expected use from the current RWR equations. These differences are outlined in Table 1. Multi-family Due to the complexity of compiling and verifying water consumption data for multi-family developments, which often include multiple buildings and irrigation taps, a representative sample of developments were analyzed for this study. Multi-family residential water use, which includes both indoor and outdoor use, has seen an overall downward trend and the average annual use per unit is significantly lower than the calculated expected use from the current February 14, 2017 Page 4 RWR equations. Table 1 shows the average use per unit, as well as the change from the expected use predicted from the current RWR equations. Table 1. Summary of annual residential water use from 2006-2015 Residential Development Type Expected Use per Unit (gal/year) Average Use per Unit (gal/year) Fraction of Expected Use Single-family/Duplex 130,840 96,640 74% Multi-family 79,720 48,380 61% In an effort to realign the RWR equations to more closely reflect current use patterns, multi-variate regression models were utilized to investigate multiple variables (e.g., lot size, number of units, building square footage, number of bathrooms, and number of bedrooms) and their ability to predict water use. The results of the analyses suggest that the best models for predicting water consumption for both single-family and multi-family residential developments are those which include lot size and number of bedrooms. The correlation between number of bedrooms and indoor water use was much greater than the current method based on number of units. This analysis indicates that altering the current RWR schedules would more accurately reflect current residential water use patterns, as well as more equitably distribute those requirements across the range of development types and sizes by better reflecting actual water use. Proposed alterations to the residential RWR schedule include separate equations for single-family (and duplex) and multi-family residential developments, as well as modifying the equation to reflect expected use as a function of number of bedrooms and lot size. These changes would reduce the volume of water required under the RWR for the average residential development. Commercial Finally, the analysis considered non-residential (or commercial) water use. An analysis of non-residential water use from 1981-2015 showed that non-residential water use increased by roughly 35% shortly after the 1980s water use study, but has trended back downward since then. Non-residential water use can vary widely by the type of business (even for the same tap size). For instance, a restaurant would be expected to use more water than a hardware store, even though they may occupy otherwise similar commercial spaces of equal size and are connected to Utilities with the same tap size. It would be administratively difficult and costly for Utilities or developers to accurately estimate each non-residential development type’s water use, especially as that use can change over time as businesses evolve and come and go on a particular property. Each of the most common tap sizes from 0.75-inch to 2-inch thus have a set RWR volume. The current method of a set RWR volume for the smaller tap sizes maintains equity across different types of water users for a single tap size by setting an allotment for a maximum allowed amount of water use, and then applying a surcharge rate for use beyond the allotment. The allotment is based on 80% of the average use for a tap size. This method provides a baseline that encourages water conservation, while still allowing customers to pay for additional RWR for greater amounts of water use. This method also recognizes that a small number of high water-use businesses pull up the overall average use of all customers in that tap size. Consequently, by using 80% of the average, the numerous businesses that use much less than the average are not penalized. Funds acquired from the surcharge rate applied to use over the allotment are used to acquire more water supplies. This methodology is still applicable to current commercial development and is recommended to be continued. Table 2 shows the average annual water use by tap size, the expected use predicted by the 1980s study and used in the current calculation of RWR, as well as the fraction of expected use. The table shows that non- residential water use was less than expected for the 1-inch, 1.5-inch, and 2-inch taps, but the 0.75-inch, was near expected. Since RWR for non-residential development is determined by tap size, the RWR could be adjusted by the fraction of expected use to reflect the change in water use over time. February 14, 2017 Page 5 Table 2. Summary of annual, non-residential water use from 2006-2015 Tap Size (inches) Expected Use (gallons/year) Average Use (gallons/year) Fraction of Expected Use (%) 0.75 191,000 190,000 100% 1.0 636,000 479,000 75% 1.5 1,273,000 1,002,000 79% 2.0 2,037,000 1,678,000 82% Suggested RWR Adjustments Given the changes in water use from the expected amount per the current RWR calculations, staff recommends that the RWR calculations be adjusted to reflect the information provided above. Making these changes will reduce the overall projected amount of expected RWR the Utilities will receive in the next 50 years from about 11,900 acre-feet to about 7,700 acre-feet. More specifically, it is recommended the RWR calculations be changed to the following: Water Supply Needs In order to meet future growth, Utilities projects the need for new infrastructure and some additional water rights. The largest part of the new infrastructure would be acquisition of additional storage capacity through the Halligan Water Supply Project. The additional storage at an enlarged Halligan Reservoir would meet a large portion of the projected future demands by storing existing water rights (and water rights to be acquired in the future) during wet times for use during dry times. Other infrastructure that is projected to be needed by 2065 includes being part of facilities required to fully utilize the Utilities’ recently changed Water Supply and Storage Company shares and potential future measuring devices and by-pass facilities on the Poudre River as part of requirements for utilizing some of the Utilities water rights. Utilities also projects a longer term need (by 2065) for some additional water rights to complement the additional storage capacity. Adding the new infrastructure and water rights to the water supply portfolio will increase the Utilities’ firm yield about 7,800 acre-feet, from the existing firm yield of 30,800 acre-feet to about 38,600 acre-feet. This boost in firm yield will meet the expected future growth for the Utilities water service area mentioned above. The new February 14, 2017 Page 6 infrastructure is estimated to cost approximately $63.9 million and the additional water rights about $25.5 million, both of which include a 25 percent contingency and total about $89.4 million. Other Costs for Increasing Firm Yield In addition to the new infrastructure and water rights mentioned above, future Utilities customers will benefit from the existing water supply portfolio. Alone, acquiring the new infrastructure and water rights mentioned above would not provide adequate water supplies needed for those future customers without use of the existing water supply system. Also, the future water supply needs for new development are being reduced by leveraging the capacity in the existing water rights system that is largely the result of effective water conservation from existing customers. In addition, new customers will have an impact on the existing water supply system through its increased use. These factors justify a partial “buy-in” to the existing system. Adding a “buy-in” charge for the future customer’s use of a portion of the water supply system will reduce future costs associated with upkeep of the water supply system, part of which results from development. Funds raised by this “buy-in” portion of the impact fee also ensures that a portion of the Utilities Water Fund reserves are replenished for water system improvements that help to reduce future rate increases for all customers by offsetting the impacts from development (e.g., helping to recover costs for the recent $8 million Michigan Ditch tunnel project). Adding the new infrastructure and water rights will increase the Utilities’ water supply firm yield from 30,800 to 38,600 acre-feet. This 7,800 acre-foot increase is about 20 percent of the future firm yield. A reasonable method of determining the portion of the existing portfolio used by future development would be to assume they use the same proportion (about 20 percent) of the existing firm yield of 30,800 acre-feet (or about 6,200 acre-feet). Applying the long-standing CIL rate of $6,500 per acre-foot to the approximate 6,200 acre-feet, results in a value of the portion of the existing portfolio that can be utilized by new development of about $40.5 million. This method minimizes the buy-in cost by only considering a certain portion of the water supply system (the most recently acquired ditch company shares) and does not factor in the higher value of other portions of the system (such as CBT units or senior water rights - all of which will be used by new development). Combining the costs of the new infrastructure and water rights needed with the value of the existing water supply portfolio gives the total cost to increase the firm yield for new development (or redevelopment) of approximately $129.9 million. Cash Only Considerations It is imperative that the RWR become a “cash only” system. This would mean no longer accepting water rights to meet the RWR. However, the existing City-issued water certificates, as well as credits from previously satisfied RWR, will still be accepted. This cash only system would recognize the importance of acquiring additional storage capacity (which cannot be turned in to meet the RWR), since such storage capacity increases our supplies by making existing (and future) water rights available during dry times. Utilities will need to focus on specific water rights in the future to avoid inefficient rights that are ineffective in our water supply system. In a cash only system, water rights could still be purchased by Utilities and focus would be given to the best water rights for our water supply system. It should be noted that Utilities plans to focus use of the cash received on infrastructure first (particularly additional storage), since it efficiently and economically provides for reliable water supplies. In addition, accepting cash only would provide flexibility to pursue other water supply options in the future, which could include regionally collaborative projects. Cash-in-Lieu (CIL) Rate Changes BBC Research and Consulting (“BBC”), which has expertise in fee and rate analyses, was hired to review the RWR system and the CIL rate. Utilities took the information provided by BBC to consider options for changes to the RWR system and CIL rate. Their attached report (Attachment 5) shows the results of their findings. As part of their study, BBC was asked to evaluate the value of the Utilities’ water supply portfolio. BBC did this by considered an equity buy-in approach for a CIL rate adjustment, where they valued the Utilities existing and future water supply system to be worth between $1.3 and $1.5 billion. Dividing that total system value by the future firm February 14, 2017 Page 7 yield of the water supply system of approximately 38,600 acre-feet determines the equity buy-in value of the water supply system. Using the low end of the total system value ($1.3 billion) results in an equity buy-in amount of about $33,800 per acre-feet of RWR. This would be an amount to “plug into” the Utilities water supply system and approximates what it would cost to acquire those supplies today. BBC also helped Utilities consider other approaches for a CIL rate adjustment. The other main option was an incremental cost approach, which considers only the costs of future water supply needs. Because the existing water rights portfolio includes water rights which will be more effectively utilized through the development of water storage and thereby will provide some water to future growth, this approach does not accurately reflect the total costs for development and would under collect the anticipated cost of developing the required water supply system. Ultimately, BBC helped Utilities identify a modified buy-in or hybrid approach that combined elements of the equity buy-in approach and an incremental cost approach. This hybrid approach involves looking at the value of existing water supply portfolio (as discussed above), the costs of future water supply needs and dividing this cost by the firm yield those future water supplies provide. Using the total costs of approximately $129.9 million, divided by the additional 7,800 acre-feet of firm yield provided, results in a hybrid approach value of about $16,700 per acre-foot of RWR. Principles of Impact Fees As staff investigated potential options for changes to the RWR system and the CIL rate, the following principles of impact fees for new development or redevelopment were followed  Growth should pay its own way. This means the impacts of the development should be paid for by the development and not by existing ratepayers via increased rates.  The impact fee should charge only the cost of mitigating the impact of the development on current customers. For example, setting the CIL to the market value of local water rights could result in charging more than is needed.  Adding the development should be done while maintaining the current level of service, with little to no impact to existing rate-paying customers. For example, reducing the drought tolerance level for existing customers by utilizing water made available through water conservation to new development could impact the level of service for existing customers. RWR and CIL Rate Changes: Options Explored Several options for changing the RWR system and the CIL rate were explored. The criteria used in considering these options included whether the option met the principles of impact fees (as explained above), was financially sustainable, and was defensible. Financial sustainability means that it will generate adequate funds to acquire the future water supply needs of the development, as well as having a reasonable and easily reproducible methodology for acquiring the funds. Lastly, defensibility is important to avoid potential risks associated with the methodologies used in any option. The following is a brief description of the different options or approaches that were investigated for changing the RWR system and CIL rate, including whether the option met the criteria mentioned above. With the exception of the first option (Status Quo), all options include going to a cash only RWR/CIL system. Status Quo: This option would involve not changing anything, including the RWR calculations, the current $6,500 CIL rate or going to a cash only system. This option does not meet any of the criteria since it does not generate adequate funds, it burdens existing customers to pay for future needs, and it asks for more water (RWR) than development needs. Existing RWR, Adjust CIL: This option would involve leaving the RWR calculations the same and adjusting the CIL rate by dividing the costs of our total future needs by the projected RWR we expect. Although this option meets the financially sustainable criteria by generating the necessary funds for acquiring the future water supply February 14, 2017 Page 8 needs mentioned above, it does not meet the other criteria since it asks for more water (RWR) than development needs. Equity buy-in approach: This option would involve adjusting the RWR calculations as recommended above and adjusting the CIL rate to the equity buy-in amount of $33,800 as explained above. Although this option partially meets the financially sustainable criteria by generating the necessary funds for acquiring the future water supply needs mentioned above, it is based on a replacement cost of the entire water supply system. Split fee approach: This option would also involve adjusting the RWR calculations as recommended above. This option would involve creating a new, additional impact fee for the necessary infrastructure needed for future water supplies, along with the current RWR fee for the water rights needed (or available to developers through existing City water certificates or credits). A variation of this option (termed a Water Right Utilization Fee) was presented to City Council during a September 24, 2013 work session. Although this option would meet most of the criteria, it potentially would create disputed issues with the use of some of the City’s water certificates and was thus not considered further. Incremental cost approach: This option involves adjusting the RWR calculations as recommended above and adjusting the CIL rate based on only the incremental costs to acquire the future water supply needs. However, because of the City’s outstanding water certificates and credits, this approach does not recognize the value of these credits to the new development and also would not generate adequate funds. Hybrid approach: This option involves adjusting the RWR calculations as recommended above and adjusting the CIL rate based as a hybrid of the incremental costs to meet the future water supply needs, along with a “buy-in” charge to future customers for the value of a portion of the Utilities’ existing water supply portfolio. By collecting sufficient revenue to meet future water supply needs associated with this growth and buying into the existing water supply system for the use of water being made available through water conservation that helps pay for the additional impacts to the existing system from new customers, this option meets all the criteria used. Thus it is the recommended option. Proposed Changes to the RWR and CIL Rate Given the information provided above, and consulting with BBC on various aspects of the RWR system and CIL rate, the best option is to use a hybrid approach. This approach would include changing the RWR calculations as suggested above. The CIL rate for this hybrid approach would be $16,700 per acre-foot of RWR. This CIL rate can be compared with about $50,000 per acre-foot of firm yield from the CBT project or with the full equity buy-in amount of $33,800 discussed above. It should be noted that the changes in the CIL rate are a significant shift from the past CIL methodology, which just looked at the incremental cost of acquiring water rights. In the future, when there may be no need for acquiring additional water supplies or infrastructure, we would likely switch to an equity buy-in approach for the CIL rate similar to the current Utilities Plant Investment Fee (PIF) structure. The recommended hybrid approach is an interim transition from an incremental to an equity buy-in approach. RWR/CIL Comparisons Table 3 shows information for the status quo (no changes) and the proposed hybrid approach, including the assumed RWR amounts, CIL rates and cost for typical developments. Although the proposed changes to the RWR schedules and CIL rates are related to impact fees specific to the Utilities water service area, a comparison with other northern Colorado water providers for single family homes and 1-inch taps are provided in Figures 1 and 2 (for illustrative purposes only). February 14, 2017 Page 9 Table 3 - Fort Collins Utilities Raw Water Requirements (RWR) for Typical Developments Development Type Status Quo (CIL=$6,500/AF) Hybrid Approach (CIL=$16,700/AF) Change from Status Quo (%) Single family, 4br, 6,000 sq ft lot Raw Water Requirement, AF: 0.66 0.54 -19.0% Total Cost, $: $4,309 $8,970 108.2% Multi-family, 100 units, 3.4 acres Raw Water Requirement, AF: 42.49 23.33 -45.1% Total Cost, $: $276,210 $389,674 41.1% Unit Cost, $/unit: $2,762 $3,897 41.1% Commercial Tap: 0.75" Raw Water Requirement, AF: 0.90 0.90 0.3% Total Cost, $: $5,850 $15,070 157.6% Commercial Tap: 1.0" Raw Water Requirement, AF: 3.00 2.27 -24.5% Total Cost, $: $19,500 $37,836 94.0% Commercial Tap: 1.5" Raw Water Requirement, AF: 6.00 4.72 -21.3% Total Cost, $: $39,000 $78,877 102.2% Commercial Tap: 2.0" Raw Water Requirement, AF: 9.60 7.91 -17.6% Total Cost, $: $62,400 $132,104 111.7% February 14, 2017 Page 10 Figure 1 $4,300 $9,000 $11,800 $13,000 $13,200 $14,200 $25,000 $0 $5,000 $10,000 $15,000 $20,000 $25,000 $30,000 Status Quo Hybrid Approach Loveland NWCWD Greeley ELCO FCLWD Cost, rounded to nearest $100 ($) Water Supply Costs for Typical Single Family Home in Northern Colorado Figure 2 $19,500 $30,600 $37,800 $62,500 $64,000 $101,100 $105,000 $0 $20,000 $40,000 $60,000 $80,000 $100,000 $120,000 Status Quo NWCWD Hybrid Approach FCLWD Greeley ELCO Loveland Cost, rounded to nearest $100 ($) Water Supply Costs for 1" Commercial Taps in Northern Colorado Future RWR/CIL Adjustments It is recommended that the CIL rate be reviewed every two years, along with the other City biennial fee review process, and adjusted as needed to reflect changes to construction costs, water rights and projected RWR (related to growth projections). February 14, 2017 Page 11 It is recommended that the RWR schedules should be reviewed every 5 to 7 years and changed if necessary, since changes to average water use are usually the result of long-term water conservation and thus less volatile than the factors underlying the CIL rate. This review would assess any potential changes in consumption, investigate the appropriateness of predictor variables, and if necessary, reflect any changes in updated equations. It is also recommended to utilize the previous 10 years of data when performing these updates. Affordable Housing Impacts Although Utilities needs the proposed changes to the RWR and CIL rate to develop adequate water supply for future development, it is recognized that these changes will increase the overall cost of housing within the Utilities water service area. These cost increases affect both Affordable Housing projects (as defined in City Code) and the affordability of housing in Fort Collins. According to the Social Sustainability Department, about 95 percent of future Affordable Housing projects will be multi-family. Although the costs for all housing (including Affordable Housing projects) in the Utilities water service area will increase with the proposed changes, the cost increases for these projects are diminished by the 39 percent reduction in the RWR calculation (for volume of water required). Utilities staff will be part of an internal task force being created by the Social Sustainability Department to analyze and address fees and housing affordability. Outreach Utilities staff presented the proposed changes to the RWR and CIL rate to the Water Board on October 6, 2016. Based on input from their meeting, Utilities staff made some changes to the proposal and postponed an October 25, 2016 City Council work session until after presenting to the Council Finance Committee and to consider timing with multiple rate changes occurring at the City (which will also be discussed during the February 14 work session). Besides the Water Board meeting in October, more recent outreach has included presenting the proposed changes to:  Week of January 23: Many of the ditch companies (during their annual stockholder meetings) from which Utilities has historically accepted shares for dedication toward meeting the RWR;  January 27: Fort Collins Chamber of Commerce  February 8: Northern Colorado Home Builders Association (did not occur before this AIS)  Various: contact with several local developers and water right holders The input gathered so far has mainly included concerns about the increased costs to housing in Fort Collins, not understanding the existing water system portion of the CIL rate, and the effect a cash only system will have on local water right values. Staff is currently working on scheduling other presentations for gathering additional input from stakeholder groups like the Fort Collins Board of Realtors and Downtown Development Authority. Also, similar outreach to City boards and commissions such as the Water Board, Economic Advisory Commission, and the Affordable Housing Board will be conducted based on the direction given by Council. The input gathered from the outreach efforts will be provided as part of the final City Council actions that will be required for adoption of changes. STAFF RECOMMENDATION Utilities staff recommends the following changes:  Adjust Raw Water Requirement (RWR) schedules to reflect recent (lower) water use o Use number of bedrooms for indoor component of residential schedule  Adjust the Cash-in-Lieu (CIL) rate per a hybrid cost approach o Increase CIL rate to $16,700 per acre-foot of requirement  Accept cash only (and existing City-issued water certificates and credits) for RWR satisfaction  Review and adjust (if necessary) the CIL rate biennially  Review and adjust (if necessary) the RWR schedules every 5 to 7 years February 14, 2017 Page 12 In addition, it is recommended the name of this Utilities development fee be change in City Code from Raw Water Requirements to “Water Supply Requirements”, since developing adequate and reliable water supplies requires more than just acquiring “raw water”. Implementation Alternatives The following are three potential alternatives to implementing the recommended changes:  Adopt changes to RWR and CIL rate and implement immediately  Adopt changes to RWR and CIL rate, but delay implementation by a few months  Adopt changes to RWR and CIL rate, but delay implementation by several months NEXT STEPS Staff will consider City Council input and conduct additional public outreach prior to returning to City Council for final approval of the changes to the RWR and CIL, which is likely to occur in the next few months. The ongoing discussions with the surround Districts will continue and Utilities will be part of the Affordable Housing task force mentioned above. ATTACHMENTS 1. Fort Collins Area Water Districts Map (PDF) 2. Residential RWR Schedule (PDF) 3. Non-Residential RWR Schedule (PDF) 4. Water Rights and Conversion Factors (PDF) 5. BBC Research Memo re: Cash-in-Lieu charges, February 7, 2017 (PDF) 6. Glossary of Water Resources Terms (PDF) 7. Powerpoint presentation (PDF) ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! Utilities electric – stormwater – wastewater - water 700 Wood St. PO Box 580 Fort Collins, CO 80522 970.221.6700 970.221.6619 – fax 970.224.6003 TDD utilities@fcgov.com fcgov.com/utilities RESIDENTIAL RAW WATER REQUIREMENTS (RWR) SCHEDULE 1 Single Family, Duplex, & Multi-Family Effective January 1, 2016 Raw water is required for the increase in water use created by new development and to ensure a reliable source of supply in dry years. The Raw Water Requirement (RWR) formulas listed below include all residential categories: single family, duplex and multi-family dwelling units. Irrigation taps needed for common area greenbelts that are part of Single-Family developments are assessed water rights on a Non-Residential basis by tap size (see Non-Residential RWR Schedule). Irrigation taps for common area greenbelts of Multi-Family developments are not assessed additional water rights since water rights collected for the buildings include the overall net acreage of the development which contain all lots, spaces, private streets, parking and common areas. When calculating the number of acre-feet of water needed to satisfy the Raw Water Requirement (RWR), select the appropriate formula listed below. If the net acres are unknown, add the square footage of all lots together and divide by 43,560, the number of square feet in an acre of land. STANDARD RESIDENTIAL RWR FORMULA RWR = Raw Water Requirement in acre-feet Net Acres = Area of development in acres, excluding public street rights-of-way, city maintained tracts and rights-of-way, ditches, railways or other areas typically maintained by persons other than the owner of the premises or an agent of the owner. RWR = 1.92 x [(.18 x Number of Dwelling Units) + (1.2 x Net Acres)] When used for the following categories, the formula above can be simplified as shown: Single Family: RWR = .3456 + (2.304 x Net Acres) max. lot area 1/2 acre or 21,780 sq.ft. Duplex: RWR = .6912 + (2.304 x Net Acres) Multi-Family (3 units or more): RWR = (.3456 x No. of Units) + (2.304 x Net Acres) RWR MAY BE SATISFIED BY ANY ONE, OR COMBINATION OF THE FOLLOWING: x Water rights (stock) acceptable to the City based on current conversion factors x City of Fort Collins water certificates x Cash at the rate of $6,500 per acre-foot of RWR If the Raw Water Requirement (RWR) is satisfied with water stock or city water certificates, transactions are completed at the Utilities before a water service permit is issued. If satisfied with cash, payment is made at Neighborhood and Building Services upon issuance of a building permit. 1 Summarized from Sections 26-129, 26-148 and 26-150 of the Code of the City of Fort Collins. ATTACHMENT 2 Utilities electric – stormwater – wastewater - water 700 Wood St. PO Box 580 Fort Collins, CO 80522 970.221.6700 970.221.6619 – fax 970.224.6003 TDD utilities@fcgov.com fcgov.com/utilities NON-RESIDENTIAL RAW WATER REQUIREMENT (RWR) SCHEDULE 1 For Water Services Not Included in the Residential Category Effective January 1, 2016 Raw water is required for the increase in water use created by new development and to ensure a reliable source of supply in dry years. Non-residential service shall include without limitation all commercial, industrial, public entity, group housing, nursing homes, fraternities, hotels, motels, commonly owned areas, club houses, and pools. The minimum Raw Water Requirement (RWR) for water services up to 2-inches in diameter is shown below. The RWR for services 3-inch and larger are based on the applicant’s estimate of actual use, provided that such estimate is first approved and accepted by the General Manager. Options for satisfying the RWR include turning over water rights to the City in the form of water stock or city water certificates, OR paying the equivalent cash-in-lieu-of amount. Equivalent Cash Minimum Meter Size Minimum RWR Payment at Annual Allotment (inches) (acre-feet) * $6,500/acre-foot (Gallons/Year) 3/4 0.90 or $ 5,850 293,270 1 3.00 or $ 19,500 977,550 1-1/2 6.00 or $ 39,000 1,955,110 2 9.60 or $ 62,400 3,128,170 3 and above Based on use * acre-foot = 325,851 gallons of water RWR MAY BE SATISFIED BY ANY ONE, OR COMBINATION OF THE FOLLOWING: x Water rights (stock) acceptable to the City based on current conversion factors x City of Fort Collins water certificates x Cash at the rate of $6,500 per acre-foot of RWR If the RWR is satisfied with water stock or city water certificates, transactions are completed at the Utilities before a water service permit is issued (refer to schedule of water rights and conversion factors acceptable to the City). If the RWR is to be satisfied with cash, payment is made at Neighborhood and Building Services upon issuance of a building permit. ANNUAL ALLOTMENT/SURCHARGE (related to Monthly Billing) The RWR establishes an annual gallon allotment for each tap and subsequent monthly water account. A surcharge of $3.06 per 1,000 gallons will be assessed on a customer’s monthly water bill when an account uses more water in a given calendar year than the gallons allotted for a particular tap size. The surcharge rate is billed in addition to the customer’s regular monthly tiered water rate. Once the annual allotment has been exceeded and the water surcharge appears on an account, the surcharge will continue to be billed each month through the end of that calendar year. Additional water stock, city certificates, or cash may be turned in to increase the annual allotment. 1 Summarized from Sections 26-129, 26-149, and 26-150 of the Code of the City of Fort Collins. ATTACHMENT 3 Utilities electric – stormwater – wastewater - water 700 Wood St. PO Box 580 Fort Collins, CO 80522 970.221.6700 970.221.6619 – fax 970.224.6003 TDD utilities@fcgov.com fcgov.com/utilities WATER RIGHTS AND CONVERSION FACTORS ACCEPTED BY THE CITY FOR SATISFACTION OF RAW WATER REQUIREMENTS (RWR) Effective January 1, 2016 Arthur Irrigation Company (see Note) 3.442 Acre-Feet / Share Larimer County Canal No. 2 (see Note) 42.687 Acre-Feet / Share New Mercer Ditch Company (see Note) 30.236 Acre-Feet / Share North Poudre Irrigation Company 5.00 Acre-Feet / Share NCWCD Units (CBT – Colo. Big Thompson) 1.00 Acre-Feet / Unit (share) Pleasant Valley and Lake Canal Company 39.74 Acre-Feet / Share Warren Lake Reservoir Company 10.00 Acre-Feet / Share City of Fort Collins Water Certificates Face Value of Cert. (in acre-feet) City of Fort Collins Josh Ames Certificates 0.5625 Acre-Feet per certificate or each certificate can satisfy 1/8 acre of land Note: The City does not accept treasury shares (inactive shares held by these companies) as of December 18, 1992. A provision in the final decree of Water Court Case No. 92CW129 prohibits the City from acquiring such treasury shares and using them for municipal purposes. February 7, 2017 Mr. Lance Smith and Mr. Donnie Dustin Fort Collins Utilities Re: Fort Collins Utilities Cash-in-Lieu Charges for Water to Serve New Development Dear Mr. Smith and Mr. Dustin: Fort Collins Utilities (FCU) retained BBC Research & Consulting (BBC) to review its cash-in-lieu requirements for providing water service to new developments. BBC met with City of Fort Collins legal staff, and with FCU’s water resource staff, to discuss this issue and gather information. We also reviewed data and documents provided by water resources staff. This letter summarizes BBC’s analysis and evaluation based on this information. BBC’s study was intended to help FCU answer four fundamental questions: What is the appropriate method for establishing FCU’s cash-in-lieu requirements? How valuable are FCU’s water resources (e.g. water rights and raw water facilities)? How would the answers to these questions change FCU’s cash-in-lieu requirements? How can FCU update its cash-in-lieu charges in future years? The remainder of this letter provides BBC’s answers to each of these questions, Method for establishing the cash-in-lieu requirement. Based on BBC’s 2015 research for the City of Greeley, FCU currently has one of the lowest, if not the lowest, cash-in- lieu charges for water supplies to serve new residential development among the larger and faster growing communities in northern Colorado (see Appendix). However, as BBC discussed with the City attorney’s office, the legal framework for impact fees —such as cash-in-lieu charges — is clear. These fees or charges cannot be based on an evaluation of what other utilities, even in the same “neighborhood”, are charging. Instead, it must be based on a fair apportionment of the utility’s own costs to serve new development. ATTACHMENT 5 PAGE 2 Courts have recognized two approaches to establishing impact fees such as cash-in-lieu charges — the equity buy-in approach and the incremental cost approach. Equity buy-in approach. This approach is often used in circumstances where the public entity or utility has available capacity to serve at least a portion of the needs required by new development. In such circumstances, the buy-in approach places an overall value on the existing system, and then calculates the share of that system that will be used by new development to determine the buy-in charge. In most years, FCU appears to have enough water rights to be able to serve foreseeable future development. However, to meet its buildout water demands under drought conditions, FCU will also require the “firming” that the proposed storage project would provide, along with other infrastructure improvements and selected additional water rights to optimize the water resource portfolio.1 Given FCU’s specific circumstances, the appropriate method for establishing potential cash-in- lieu charges under the buy-in approach is to estimate the value of the combined water rights and storage system when the system is fully completed (e.g., after the proposed storage project and other infrastructure projects are developed and remaining water rights are purchased). The ultimate value of the system can then be apportioned between new development and existing customers based on the firm yield of the system and the firm yield requirements of the customers. This approach implicitly recognizes that both existing and new customers will benefit from the new storage project and other additions to the water resource portfolio, as well as from the existing water rights portfolio, and treats these customers in the same fashion. It also avoids the need for a complicated, and potentially controversial, apportionment of the values of existing and new water supply components between new and existing customers. Incremental cost approach. One important disadvantage of the equity buy-in approach, specific to FCU’s situation, is that it may raise more money than is actually needed for the future projects and water rights acquisitions required to complete the water supply system for buildout demand. As discussed in greater detail later in this report, this situation arises because the future projects FCU is developing are highly efficient (from an economic standpoint) and can provide additional firm yield at a lower cost per acre foot than the existing system can currently deliver. Under these circumstances, FCU may want to consider establishing its cash-in-lieu charges based on an incremental cost approach, the most common alternative to the equity buy-in approach in setting impact-type fees. The incremental cost approach considers only the additional cost that a public entity (or utility) must pay in order to increase its capacity to serve 1 In addition to the enlargement of Halligan Reservoir (or similar), FCU anticipates participating with other municipalities in a management project for the use of converted Water Supply and Storage Company shares, potential future measuring devices and by-pass facilities on the Poudre River, and obtaining some additional water rights. PAGE 3 new development while maintaining the same level of service that it currently provides to its existing customers. Estimated value of FCU’s water resource system. From the standpoint of this analysis, there are two basic components in the water resource portfolio required to serve FCU’s existing customers and new development: FCU’s existing water rights and storage facilities, and the proposed new storage project and other anticipated projects and water rights needed to complete the water supply system. Estimated minimum value of FCU’s existing water resource portfolio. As detailed in Figure 1 on the following page, BBC’s minimum estimate of the current value of Fort Collins existing water rights and storage facilities is approximately $1.2 billion. This minimum value estimate is reasonably consistent with the value of “around $1 billion” cited in the 2012 Update to the Water Supply and Demand Management Policy Report.2 BBC is familiar with the current active markets for three of the larger water rights holdings in FCU’s portfolio – Colorado-Big Thompson Units (C-BT), shares in the North Poudre Irrigation Company (NPIC), and shares in the Water Supply and Storage Company (WSSC). Based on recent market values for these supplies, BBC estimates the current market value for this portion of FCU’s water rights portfolio to be about $800 million. Most of the other water rights and storage facilities in FCU’s portfolio do not have well defined markets, and in some cases may not have been traded at all in recent years. To obtain an estimate of the overall value of FCU’s portfolio, BBC has developed minimum and maximum estimates of the value of these other rights and facilities based on our experience with other water supplies used by Colorado’s Front Range communities. The largest contributor to the remaining value of FCU’s water resource portfolio (excluding the well-defined sources described previously) is its Poudre River direct flow rights. Most of these are very senior water rights that yield nearly as much supply during dry years as under average or “normal” hydrologic conditions. Senior direct flow rights such as these are very seldom, if ever, traded – though there would undoubtedly be a substantial market for them if they became available. To develop a minimum estimate of the value of FCU’s water rights portfolio, we have conservatively assumed a value for these rights of $20,000 per acre foot of average yield – corresponding to a total value of $226 million for these rights. FCU’s other water rights and facilities that can currently contribute to its treated water supply include its Reuse Plan arrangement with Platte River Power Authority, its Joe Wright-Michigan Ditch System, its shares in the Pleasant Valley & Lake Canal Company and the Chaffee Ditch, and shares in a number of other irrigation systems sometime referred to as the “South Side Ditches.” 2 See page 28 of the 2012 report. PAGE 4 These systems include the Arthur Irrigation Company, Larimer County Canal No. 2, the New Mercer Ditch Company, and the Warren Lake Reservoir Company. While BBC is not aware of any recent transactions involving any of these supply sources, we believe the value of the supply from the Reuse Plan may be roughly equivalent to the value of shares in the recent Windy Gap Firming Project, or approximately $25,000 per acre foot of yield. The shares in the Joe Wright-Michigan Ditch System are firmed by storage, and likely are worth at least $10,000 per acre foot. We believe a conservative, minimum value estimate for the remaining treatable water supplies would be about $5,000 per acre foot of average annual yield. Combining the various minimum value estimates described above, BBC believes a current, minimum value for FCU’s existing water resource portfolio is about $1.23 billion. Estimated minimum value of anticipated additions to water resource portfolio. As discussed previously, FCU anticipates the completion of several infrastructure projects and the purchase of selected additional water rights to complete the system and serve buildout demands. FCU projects the expansion of Halligan Reservoir will ultimately cost approximately $46.2 million, FCU’s participation in the WSSC management project is roughly estimated to cost about $2.6 million, development of future measuring devices and by-pass facilities on the Poudre River is anticipated to cost approximately $2.3 million and the future water rights purchases are projected to cost about $20.4 million. These cost estimates for future additions total approximately $71.5 million. To develop the minimum estimate of these future costs, BBC removed contingency factors previously estimated by FCU from the cost projections. Adding these projected costs for additions to the water supply system, BBC’s minimum estimate of the current value of the ultimate system is about $1.31 billion. PAGE 5 Figure 1. Estimated Minimum Value of FCU’s Water Resource System Notes: a/ Current market price -- high by historic standards. b/ Latest data from FCU. Generally trades at value of embedded C-BT (3 units, after shrink). c/ Approximate 2015 value, may be higher now. d/ Min. estimate of value. These types of WR don't trade, but are very firm. e/ Firm/reusable supply. Value est. based on WGFP. f/ Value includes storage and firming. g/ No known market for most of these. This is an estimated minimum value. Includes PV&LCC and Chaffee Ditch. h/ Latest estimate from FCU, excludes contingencies. Volume Average Supply Source (Shares) Yield per Share per AF Total Value Current System in 2016 Known Market Values C-BT 18,855 14,330 $25,000 $32,894 $471,375,000 a/ NPIC 3,564 19,850 $88,000 $15,799 $313,610,000 b/ WSSC 27 2,240 $600,000 $7,144 $16,002,000 c/ Subtotal 36,420 $21,993 $800,987,000 Estimated Minimum Market Values Poudre River Direct Flow 11,300 $20,000 $226,000,000 d/ PRPA Reuse Water 2,310 $25,000 $57,750,000 e/ Joe Wright/Michigan Ditch 5,500 $10,000 $55,000,000 f/ Other Sources Available for Treatment 18,970 $5,000 $94,850,000 g/ Total Minimum Estimated Value for Current System 74,500 $16,572 $1,234,587,000 Future System Additions Future Water Rights Acquisitions $20,400,000 h/ Infrastructure Projects Proposed Firming Project (Halligan) $46,200,000 h/ WSSC Management Project $2,600,000 h/ River By-pass Facilities $2,300,000 h/ Minimum Value for Future System Additions $71,500,000 Minimum Estimated Value for Completed System $1,306,087,000 Estimated Value PAGE 6 Potential maximum value of FCU’s water resource portfolio. To estimate the current, maximum value of the portfolio, BBC made the following modifications to the previous minimum value assumptions. First, we assumed the Poudre River direct flow rights could be worth as much as $30,000 per acre-foot, approximately on par with the current value of C-BT supplies on an average annual yield basis. We added 25 percent to the minimum value estimates for supplies from the PRPA Reuse Plan and Joe Wright/Michigan Ditch System. We also assumed a maximum value for the collection of other water rights and facilities that provide water available for treatment (excluding C-BT, NPIC and WSSC supplies) of $7,500 per acre foot of average annual yield (rather than the $5,000 per acre foot estimate used to derive the minimum value estimate). For the future system additions, we included a 25 percent contingency factor on the projected costs for infrastructure and water supply additions to the water resource portfolio (e.g. Halligan Reservoir expansion, WSSC Management Project, river measurement and by-pass facilities and selected water rights acquisitions). With these modified assumptions, we derive a potential maximum value for the ultimate water resource portfolio of about $1.51 billion, as shown in Table 2. PAGE 7 Figure 2. Estimate Range of Potential Values for FCU’s Water Resource System Value per acre-foot of firm yield. Figure 3 summarizes the value estimates for Fort Collins water resource portfolio, and converts those estimates into values per acre-foot of firm yield. The anticipated additions to the portfolio are expected to add substantially to the firm yield of the system — increasing total firm yield from about 30,800 AFY to 38,600 AFY — at a comparatively low cost. The current estimate of the ultimate value of the completed system is between $33,800 and $39,200 per acre-foot. Supply Source Minimum Maximum Difference Current System in 2016 Known Market Values C-BT $471,375,000 $471,375,000 $0 NPIC $313,610,000 $313,610,000 $0 WSSC $16,002,000 $16,002,000 $0 Subtotal $800,987,000 $800,987,000 $0 Other Water Resources Poudre River Direct Flow $226,000,000 $339,000,000 $113,000,000 PRPA Reuse Water $57,750,000 $72,187,500 $14,437,500 Joe Wright/Michigan Ditch $55,000,000 $68,750,000 $13,750,000 Other Sources Available for $94,850,000 $142,275,000 $47,425,000 Treatment Total for Current System $1,234,587,000 $1,423,199,500 $188,612,500 Future System Additions Proposed Firming Project (Halligan) $46,200,000 $57,750,000 $11,550,000 WSSC Management Project $2,600,000 $3,250,000 $650,000 River By-pass Facilities $2,300,000 $2,875,000 $575,000 Future Water Rights Acquisitions $20,400,000 $25,500,000 $5,100,000 Totals for Completed System $1,306,087,000 $1,512,574,500 $206,487,500 Estimated Range of Values PAGE 8 Figure 3. Range of Value and Estimated Value per Acre-foot of Firm Yield Potential Cash-in-Lieu Charges for New Development. BBC reviewed FCU’s current approach for establishing cash-in-lieu fees for new development and developed recommendations regarding potential modifications. FCU’s current approach. FCU currently determines the raw water requirements (RWR) for new residential development based on a formula established in the 1980s. That formula, which can be applied to detached single family residential developments, duplexes or multifamily developments, is: RWR = 1.92 x [(.18 x Number of Dwelling Units) + (1.2 x Net Acres)] For single family residential developments, the formula simplifies to: RWR = .3456 + (2.304 x Net Acres)3 The RWR for commercial developments is based on meter size, with specified RWR volumes (or corresponding cash-in-lieu charges) for commercial properties that will use ¾ inch to 2 inch taps. RWR for facilities requiring taps larger than 2 inches are determined through a case-by- case evaluation. BBC has focused primarily on the RWR for single family residential development. At least some of our observations, however, may also apply to the RWR for other types of development. Conceptual approach to establishing RWR. During a previous assignment for the City of Greeley in 2015, BBC reviewed the residential water dedication and cash-in-lieu requirements for the 22 of the largest and fastest growing municipal water providers in the northern Front 3 The formula is subject to the restriction that the maximum lot area not exceed ½ acre. Current System Anticipated Additions Completed System Estimated Value Minimum $1,234,587,000 $71,500,000 $1,306,087,000 Maximum $1,423,199,500 $89,375,000 $1,512,574,500 Firm Yield (AFY) 30,800 7,800 38,600 Value per AFY Minimum $40,084 $9,167 $33,836 Maximum $46,208 $11,458 $39,186 PAGE 9 Range. That review, which included FCU, found that 19 of the 22 communities impose a water dedication requirement and/or a cash-in-lieu fee for water resources for new residential developments in their service areas.4 While the volume of water required for new development varied among the communities included in BBC’s prior evaluation, there were three basic methods of determining the amount of water to be dedicated for residential development (and/or the corresponding cash-in-lieu charge). Requirement based on overall gross or net acreage of new development. This was the simplest approach for establishing the amount of water to be dedicated (or the total cash- in-lieu charge). Greeley, Longmont and Windsor use this approach. Requirement based on number of dwelling units or taps. This method, which does not account for differences in lot size5, was the most common approach for establishing the water dedication/CIL volume. Northern Colorado water providers using this approach included Broomfield, Dacono, Eaton, Erie, Evans, Fort Collins-Loveland Water District, Fort Lupton, Frederick, Johnstown, Lafayette, Left Hand Water District and Severance. Requirement based on number of units and lot size. FCU, along with three other northern Colorado water providers, factor in both the number of dwelling units and their lot size to determine the water dedication requirements. Apart from FCU, the providers using this approach were Firestone, Loveland and North Weld County Water District. Two of the providers (Firestone and North Weld County Water District) specify three or more ranges of lot sizes with differing water dedication requirements for each range. Loveland uses a formula more similar to FCUs, but with different coefficients for lots below or above 15,000 square feet. Fort Collins has recently decided to switch from the number of units to the number of bedrooms in establishing their water dedication requirements. By considering the number of bedrooms and lot sizes, the approach used by FCU (similar to the other three providers mentioned in the last bullet above which include number of units and lot size) explicitly recognizes the separate indoor and outdoor aspects of residential water use. In our view, this approach to determining the water dedication requirement is the most conceptually sound of the three basic methods. 4 The three communities that do not levy a specific water dedication/cash-in-lieu fee were Boulder, Central Weld County Water District and Louisville. However, these three communities also levied the highest plant investment fees (PIFs) for new residential water service in the region – suggesting they are recovering water resource-related costs through their PIFs. 5 Some of these providers do distinguish between 5/8” taps and ¾” taps, which could be associated with differences in lot size. PAGE 10 Findings and recommendations. BBC believes FCU should revise its cash-in-lieu charges at this time, and makes the following recommendations. The water usage assumptions (developed more than 20 years ago) should be adjusted to reflect changes in water use per account. The formulas that FCU uses to establish RWR and cash-in-lieu requirements are theoretically sound. The “water supply factor” (the 1.92 term in the RWR formulas) likely remains appropriate to provide a contingency for increased demand under drought conditions, treatment and distribution water losses and other factors. Note: FCU has undertaken this analysis and determined more recent water use requirements for different types of uses. For example, single family residential requirements appear to have declined by at least 25 percent, relative to the assumptions built into the current RWR equations. FCU should convert to a cash only system for providing water resources for new development. FCU has specific plans for completing its water resource system, and these plans are highly efficient from an economic standpoint (as shown previously in Figure 2). What FCU needs is cash to pay for these plans, rather than additional water rights that do not necessarily best suit system needs. We recognize, however, that FCU has previously provided a number of water development credits (e.g. water certificates and credit accounts) that will need to be accommodated. The cash-in-lieu equivalent value should be revised. BBC believes FCU could be justified in charging as much as the full buy-in value for the completed water system (e.g. between $33,800 and $39,200 per acre-foot of firm yield requirements). However, we also recognize that setting the cash-in-lieu charge at this level would both represent a significant change from the current charge and may impact economic development more severely than other approaches discussed below. The incremental cost approach, outlined on page 2 of this report, may be a more practicable alternative to setting the revised cash-in-lieu value. This approach would establish the cash-in- lieu charge at a level sufficient to simply fund the anticipated additions to the water supply system. To implement this approach, FCU would need to estimate the raw water requirements for future development, net of the requirements likely to be met from non-cash sources (e.g. outstanding credits and credits for redeveloped properties). FCU would then divide the projected costs for completing the system (between $72 and $89 million per Figure 3) by the projected net raw water requirements to establish the cash in lieu charge per acre foot. Inherent in the incremental cost approach is the recognition that the incremental costs are being reduced by leveraging the excess capacity in the existing water rights portfolio that is the result of effective water conservation from existing customers. As such, the incremental cost approach understates the full cost of new development by not recognizing the value of the portion of the existing water rights portfolio which will be leverage to serve such growth. PAGE 11 To address this understatement of the full cost of new growth, FCU could also consider a modified “buy-in” or hybrid approach. Under such an approach, the cash-in-lieu charge would include the incremental cost of anticipated additions to the system (as described above) – along with an additional charge to capture some of the benefit new development will also receive from using FCU’s existing water rights and facilities. For example, FCU has estimated that new development will use about 6,200 acre-feet of the firm yield of the existing system (prior to the anticipated system additions). Although FCU could be justified to charge as much at the full buy- in value of the City’s existing system (e.g., between $33,800 and $39,200 per acre-foot) for this existing component of their system, it could consider charging less (e.g., the FCU’s historic CIL charge of $6,500 per acre-foot), which would result in an additional charge to new development for use of the existing water rights system of approximately $40.5 million. When added to the incremental costs for system additions anticipated by FCU, the combined amount of revenue to be required under this hybrid approach would be between $112.0 and $129.9 million. Based on FCU’s updated estimate of the water requirements to serve future new development (7,800 AF), the revised CIL charge under this version of a hybrid approach would be between $14,400 and $16,700 per acre-foot of raw water requirements. Figure 4. Potential Cash-in-Lieu Charges based on Alternative Approaches Notes: * Based on projected average RWR of 0.54 acre-feet per new home. Updating FCU’s cash-in-lieu charges in the future. Assuming FCU implements the modified “buy-in” or hybrid approach just described, or a similar revision to its current charges, it will likely wish to update those charges more frequently than it has done in the past. There are basically two fundamental elements to the proposed charge based on the incremental or hybrid approaches discussed above — the raw water requirements (volume of water required) and the cash equivalent value. BBC believes the raw water requirement element should be reviewed every five to ten years to detect fundamental changes in water usage patterns. More frequent reviews may not be productive, due to the inevitable variability in year to year water use due to changing summer weather conditions. "Buy-In" Incremental Modified "Buy-in" Approach Approach or "Hybrid" Approach Value per Acre-foot Minimum $33,800 $9,200 $14,400 Maximum $39,200 $11,500 $16,700 Average Value per New Home* Minimum $18,300 $5,000 $7,800 Maximum $21,200 $6,200 $9,000 PAGE 12 The full buy-in approach, based on the overall value of FCU’s water resources, establishes the maximum value per acre-foot that FCU could use in setting its cash-in-lieu charges. Given the relatively high values that result from the full buy-in approach ($33,800 to $39,200 per acre- foot, as described on page 7) compared to the expected charges that would result from the incremental or hybrid approaches, it is not likely to be necessary for FCU to reappraise the value of its full water resource portfolio on a regular basis. Since the price of C-BT units is the only value in the overall water resource valuation that is routinely updated and publicly available, FCU might require consulting assistance if and when it does decide to update the estimated value of its overall water resource portfolio. Fortunately, updating the cash-in-lieu charge based on the incremental or hybrid approaches is easier than updating the estimated value of the overall water resource portfolio. Under the incremental approach, the cash equivalent value is primarily determined by cost of future additions to the system, divided by the raw water requirements expected to be met with cash- in-lieu payments. The hybrid approach is determined in a similar fashion to the incremental approach, but just adds the existing value component to the numerator of the equation. FCU is likely to continue to update and refine the cost estimates for the Halligan Reservoir Expansion, and other anticipated infrastructure projects, and can use these updated estimates to update the cash-in-lieu charge as needed. BBC believes the cash-in-lieu charge should be reviewed and approved by the City’s policymakers on an annual basis as a matter of sound policy, but recalculation of the charge should only be necessary if there appear to be substantial changes in raw water requirements or the costs of completing the system. It is worth noting that many of the other water providers in the Northern Front Range set and adjust their cash-in-lieu charges based on the price of C-BT. While this may be appropriate for water providers whose primary supply is C-BT, we do not believe it is an appropriate benchmark for FCU. Further, the dwindling number of C-BT units available for transfer has helped fuel a rapid escalation in C-BT prices in recent years, and we believe C-BT prices may become increasingly unstable in the future as that particular source of supply becomes more and more scarce. Sincerely, Douglas L. Jeavons Managing Director PAGE 13 Appendix – Cost of Obtaining Residential Water Service from Northern Colorado Water Providers (from BBC’s 2015 study for City of Greeley) City of Fort Collins Utilities Changes to the Utilities Raw Water Requirements City Council Work Session February 14, 2017 Glossary of Water Resources Terms 1-in-50 Year Drought Criterion - criterion adopted in the current Water Supply and Demand Management Policy that defines the level of risk for the City’s water supply system; a drought is a period of below average runoff that can last one or more years and is often measured by its duration, average annual shortage and cumulative deficit below the average; a 1-in-50 drought corresponds to a dry period that is likely to occur, on average, once every 50 years; although the Poudre River Basin has several drought periods in its recorded history, it is difficult to assess whether any of these droughts were equal in magnitude to a 1-in-50 drought; the 1985 Drought Study developed the 1-in-50 drought used in assessing the Utilities water supply system; this drought period is six years long and has a cumulative deficit of 550,000 acre-feet, which represents annual river volumes that are about 70% of the long-term average for the Poudre River; see also “Statistically Based Drought Analysis” Acre-Foot or Acre-Feet (AF) - volume of water equal to about 326,000 gallons; one acre- foot can supply around three to four single family homes in Fort Collins per year; for storage comparison the maximum volume of Horsetooth Reservoir is about 157,000 acre- feet Active Capacity - the usable capacity of a reservoir for storage and regulation of inflows and releases that does not include any capacity below the reservoir’s lowest outlet (which is known as dead capacity) Cash-in-lieu rate (CIL) - the cash equivalent of the water supply required to meet the needs of development; see also Raw Water Requirements Carryover - used in reference to storage; it is the ability to save water in storage for use at a later time, most notably in following years Change in Water Right - used to refer to changing water rights under Colorado water law from agricultural to municipal water use; see also “Legal Return Flows or Return Flow Obligations” CIP - Capital Improvement Project, which typically refers to a project to improve Utilities facilities (e.g., treatment plant capacity expansion) Colorado-Big Thompson (CBT) Project - a Bureau of Reclamation project that brings water from the Colorado River basin to the east side of the continental divide via a tunnel and the Big Thompson River to several locations including Horsetooth Reservoir; 1 ATTACHMENT 6 operated by the Northern Colorado Water Conservancy District (or Northern Water); Fort Collins Utilities currently owns 18,855 units of the 310,000 total units in the CBT project Cubic Feet per Second (cfs) - volumetric flow rate equal to one cubic foot flowing every second; for comparison, an average peak flow rate on the Poudre River at the Lincoln Street gage (downtown) is around 1,900 cfs and a median winter-time low flow rate in December at the same location is around 7 cfs Direct Flow Rights - water rights that can be taken for direct use, as opposed to storage rights that can be taken for later use; see also “Senior Water Rights” DEIS or EIS - Draft Environmental Impact Statement or Environmental Impact Statement; a report detailing the findings of the NEPA permitting process; report can be reviewed by public for their comments which are typically addressed in a Final Environment Impact Statement; see also “NEPA” ELCO - East Larimer County Water District; see also “Tri-Districts” FCLWD - Fort Collins-Loveland Water District; see also “Tri-Districts” Firm Yield - a measure of the ability of a water supply system to meet water demands through a series of drought years; for the Fort Collins Utilities, this means being able to meet the planning demand level and storage reserve factor through the 1-in-50 year drought criterion; see also “1-in-50 Year Drought Criterion”, “planning demand level” and “storage reserve factor” GMA - short for Growth Management Area, which is the planned boundary of the City of Fort Collins’ future City limits gpcd - gallons per capita per day; a measurement of municipal water use; for the Fort Collins Utilities, gpcd is calculated based on the total annual treated water produced at the Water Treatment Facility for use by all Water Utility customers (minus large contractual customers and other sales or exchange agreements) divided by the estimated population of the Water Utility’s service area and 365 days LEDPA - Least Environmentally Damaging Practicable Alternative, which is what is allowed to be permitted through the NEPA permitting process; see also “NEPA” Legal Return Flows or Return Flow Obligations - refers to legal requirements when changing water rights from agricultural to municipal use; this process requires obtaining a decree from Colorado Water Court that involves detailed analysis of the historic agricultural water use, including the water diversions, amount used by the crops, and the return flow patterns of the water not used by the crops; terms in the decree to prevent municipalities from taking more water than was historically taken and replacing return flows in the right amount, location and time to prevent injury to other water rights 2 NEPA - National Environmental Policy Act; federal legislation that established environmental policy for the nation; it provides interdisciplinary framework for federal agencies to prevent environmental damage and contains “action-forcing” procedures to ensure that federal agency decision-makers take environmental factors into account NISP - Northern Integrated Supply Project Northern Water or NCWCD - short for Northern Colorado Water Conservancy District (NCWCD); Northern Water operates the Colorado-Big Thompson (CBT) Project and is involved in several other regional water projects on behalf of their participants; see also “Colorado-Big Thompson (CBT) Project” NPIC - North Poudre Irrigation Company; an irrigation company that supplies water to farmers north of Fort Collins and is the owner of all water currently stored in Halligan Reservoir; the City currently owns about 36% of the shares in the company NWCWD - North Weld County Water District; see also “Tri-Districts” Planning Demand Level - level of water use (demand) in gpcd used for water supply planning purposes that is a factor in determining the amount of water supplies and/or facilities needed; see also “gpcd” PIF (or PIFs) - Plant Investment Fee(s), which are one-time fees assessed on developments for the cost of the utility infrastructure needed to serve that development Raw Water Requirement (RWR) - requires new development to turn in water rights, a payment of cash-in-lieu of water rights, or use of City-issued water certificates or credits to support the water needs of that development; cash is used to increase the firm yield and long-term reliability of the City’s supply system (e.g., purchase additional storage capacity) Storage Reserve Factor - refers to a commonly used engineering principle in designing water supply systems to address short-term supply interruptions; as defined in the Water Supply and Demand Management Policy, the storage reserve factor incorporates having 20 percent of annual demands in storage through the 1-in-50 drought which equates to about 3.5 months of winter (indoor) demands or 1.5 month of summer demands Senior Water Rights - refers to Colorado water law’s use of the “prior appropriation” or priority system, which dictates that in times of short supply, earlier water rights decrees (senior rights) will get their water before others (junior rights) can begin to use water, often described as “first in time, first in right” Southside Ditches - refers to the irrigation ditches that run through the City of Fort Collins, including the Arthur Ditch, New Mercer Ditch, Larimer County Canal No. 2 and Warren Lake Reservoir; the Pleasant Valley and Lake Canal is another ditch that runs through Fort Collins and is sometimes considered a Southside Ditch 3 Tri-Districts - the combination of the three regional water districts East Larimer County (ELCO), Fort Collins-Loveland (FCLWD) and North Weld County (NWCWD) Water Districts; these districts share the same water treatment plant called Soldier Canyon Filter Plant, which is located adjacent to Fort Collins Utilities’ Water Treatment Facility Water Rights Portfolio - the mix of water rights owned by a water supplier; typically includes water for direct use, as well as for storage for later use; for the Fort Collins Utilities, includes City owned water rights, owned and/or converted shares in agricultural rights, storage rights at Joe Wright Reservoir, and ownership in the CBT project Water Supply Factor - refers to a multiplying factor used in the assessment of raw water required by developers to reflect issues that tend to reduce the average yield of the water supplies provided to a water supplier (e.g., system losses, variable demands, etc.) WSDMP - short for Water Supply & Demand Management Policy, which provides Fort Collins Utilities guidance in balancing water supplies and demands Yield or Water Rights Yield - refers to the amount of water that is produced from a water right; the yield of water rights vary from year to year depending on the amount of water available (i.e., low or high river runoff) and the priority of the water right; see also “Firm Yield” and “Senior Water Rights” 4 1 Changes to the Utilities Raw Water Requirements Donnie Dustin, P.E., Water Resources Manager City Council Work Session February 14, 2017 HORSETOOTH RESERVOIR 2 Water Fees PLANT INVESTMENT FEES (PIF) DISTRIBUTION WATER TREATMENT TAP FEES (Water Meters) WATER METERS RAW WATER REQUIREMENTS (RWR) Source of Supply (water rights), which includes Storage and Transmission CACHE LA WATER POUDRE RIVER SUPPLY HORSETOOTH RESERVOIR 3 This work session focuses on Utilities water service area; continued discussions with other districts. Raw Water Requirements What are they? • Water rights or fee paid by new development • Amount based on use, type of development • GOAL: generate adequate funds and water rights to provide reliable water supply 4 Current Satisfaction of RWR RWR can be satisfied with: • Acceptable water rights • Cash-in-lieu of water rights • City certificates (credits) • Combination 5 Market Value of Colorado- Big Thompson (CBT) Project Units 6 0 50 100 150 200 250 300 $0 $5,000 $10,000 $15,000 $20,000 $25,000 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 Average Daily Use per Capita (gpcd) Cost Year Colorado-Big Thompson Project Unit Price vs. Fort Collins Utilities Use, Cash-in-Lieu Rate C-BT Price ($/unit) FCU CIL ($/AF) FCU Average Use Per Capita (gpcd) 6 Timeline 7 Water Rights Utilization Fee Discontinued Water Banking Year of Water – Started Evaluation of RWR Changes Water Board and Canceled Council Work Session Council Finance Committee 2013 2014 2015 2016 Jan. 2017 Overview 8 Changes Recommended: • Amount of Raw Water Requirement • Cash-in-Lieu Rate • Accepting Cash Only 9 Amount of Raw Water Required Amount of Raw Water Requirement (RWR) Future Development/RWR How much firm yield is needed for future development? • Growth in service area • Population increase ~45,000 by 2065 • Residential and commercial water use • Expected RWR from growth: • ~11,900 AF of RWR (current calculation) • But, water use has changed over time 10 Water Use Changes How has water use changed? • Analyzed 10 years water use (2006-2015) • Water use less than expected (current RWR) • Single-family: 26% less • Multi-family: 39% less • 3/4-inch tap: little change • Larger taps: 18-25% less • Suggest RWR adjustments to reflect changes • Revised expected RWR = ~7,700 AF 11 Residential indoor use better correlated to number of bedrooms 12 Amount Cash-in-of Raw Lieu Water (CIL) Required Rate Cash-in-Lieu: Past, Future, Present • Past: accepted water rights and cash-in-lieu • Incremental cost of water rights • Future: water supply system complete • Equity buy-in cost approach • Similar to plant investment fees • Present: transition from incremental to buy-in • Hybrid of both 13 Future Water Supply Needs How much will it cost to increase firm yield for new development? $63.9M: Infrastructure (e.g., storage) + $25.5M: Future water rights (requires storage) + $40.5M: Value from existing portfolio $129.9M: Total cost to increase firm yield 14 Future supplies would not provide adequate yield without existing portfolio Hybrid Cost Approach • Proposed Cash-in-lieu rate: = $16,700 / AF 𝑉𝑉𝑉𝑉𝑉𝑉𝑉𝑉𝑉𝑉 𝑜𝑜𝑜𝑜 𝐹𝐹𝑉𝑉𝐹𝐹𝑉𝑉𝐹𝐹𝑉𝑉 𝐼𝐼𝐼𝐼𝐼𝐼𝑉𝑉𝐼𝐼𝐹𝐹𝐼𝐼𝑉𝑉𝐼𝐼𝐹𝐹 𝐼𝐼𝐼𝐼𝐼𝐼𝐹𝐹𝑉𝑉𝑉𝑉𝐼𝐼𝑉𝑉𝐼𝐼 𝐹𝐹𝐹𝐹𝐹𝐹𝐼𝐼 𝑌𝑌𝐹𝐹𝑉𝑉𝑉𝑉𝐼𝐼 = $129.9𝑀𝑀 7,800 𝐴𝐴𝐹𝐹 Cash-in-lieu Rate 15 Value from Existing Portfolio 16 30,800 AF 7,800 AF 0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 Supplies Firm Yield (acre-feet) Future Development Current Customers How is this portion of the fee calculated? • ~20% of existing firm yield and historic CIL rate of $6,500/AF • Compares with CBT = $50,000/AF • Less than full “buy-in” with future needs = $33,800/AF How will funds be used? • Offsets future impacts on existing water supply system (e.g., Michigan Ditch tunnel) Future Firm Yield = 38,600 AF 17 17 $4,300 $2,800 $9,000 $3,900 $0 $1,000 $2,000 $3,000 $4,000 $5,000 $6,000 $7,000 $8,000 $9,000 $10,000 Single family, 4br, 6,000 sq ft lot Multi-family, 100 units, 3.4 acres Cost per Unit or Tap ($) Fort Collins Utilities: Raw Water Requirement Costs for Typical Residential Developments Status Quo Hybrid Approach Cash-in-lieu (CIL) Rates: Status Quo CIL = $6,500/AF Proposed CIL = $16,700/AF 18 18 $5,900 $19,500 $15,100 $37,800 $0 $10,000 $20,000 $30,000 $40,000 Commercial Tap: 0.75" Commercial Tap: 1.0" Cost per Unit or Tap ($) Fort Collins Utilities: Raw Water Requirement Costs for Typical Commercial Developments Status Quo Hybrid Approach Cash-in-Lieu (CIL) Rates: Status Quo CIL = $6,500/AF Proposed Cost CIL = $16,700/AF $4,300 $9,000 $11,800 $13,000 $13,200 $14,200 $25,000 $0 $5,000 $10,000 $15,000 $20,000 $25,000 $30,000 Status Quo Hybrid Approach Loveland NWCWD Greeley ELCO FCLWD Cost, rounded to nearest $100 ($) Water Supply Costs for Typical Single Family Home in Northern Colorado 19 19 $19,500 $30,600 $37,800 $62,500 $64,000 $101,100 $105,000 $0 $20,000 $40,000 $60,000 $80,000 $100,000 $120,000 Status Quo NWCWD Hybrid Approach FCLWD Greeley ELCO Loveland Cost, rounded to nearest $100 ($) Water Supply Costs for 1" Commercial Taps in Northern Colorado 20 20 21 Amount Accepting of Raw Cash Water Only Required Accepting Cash vs. Water Rights Imperative to switch to cash-only system: 22 Focus on infrastructure first Need specific water rights in future Flexibility to pursue other options Can still acquire water rights Incorrect rights are inefficient; ineffective without infrastructure (storage) Storage increases supply with existing (and future) water rights Could include regional aspects Focus on best rights Staff Recommendations 1. Adjust RWR schedules based on recent use • Residential based on # of bedrooms 2. Use “Hybrid” approach cash-in-lieu rate • CIL = $16,700/AF of RWR 3. Accept cash only (and credits) 4. Periodically adjust CIL, RWR 5. “Water Supply Requirements” 23 Implementation Alternatives • Adopt changes and implement immediately • Adopt changes and delay implementation by a few months • Adopt changes and phase in changes over several months 24 Affordable Housing • Concern for both Affordable Housing (as defined in City Code) and housing affordability in Fort Collins • Future Affordable Housing projects are 95% multi-family • Cost for all housing will increase (in Utilities service area) • Multi-family cost impact will be lessened by reduced RWR • Social Sustainability creating an internal task force to address fees and housing affordability 25 Next Steps 26 Additional public outreach City Council action/adoption Changes become effective On-going: • Water District discussions • Affordable Housing task force Feb- Mar Apr- May Jul- Sep Direction Sought 27 What feedback does Council have on the proposal to: • Change the amount of raw water required? • Change the cash-in-lieu rate and methodology? • Accept cash only? • Require periodic updates to the RWR and CIL rate? 28 ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! INTERSTATE 25 S SHIELDS ST S COLLEGE AVE S TAFT HILL RD E VINE DR S TIMBERLINE RD LAPORTE AVE E PROSPECT RD S LEMAY AVE E DOUGLAS RD W DRAKE RD STATE HIGHWAY 392 N OVERLAND TRL E MULBERRY ST E DRAKE RD S COUNTY ROAD 5 COUNTY ROAD 54G N US HIGHWAY 287 N SHIELDS ST W MULBERRY ST W PROSPECT RD S OVERLAND TRL E COUNTY ROAD 30 ZIEGLER RD W TRILBY RD E HORSETOOTH RD N COUNTY ROAD 23 W COUNTY ROAD 38E CARPENTER RD S COUNTY ROAD 23 E LINCOLN AVE N TAFT HILL RD E COUNTY ROAD 38 W HORSETOOTH RD TURNBERRY RD W ELIZABETH ST N LEMAY AVE TERRY LAKE RD S COUNTY ROAD 19 N COUNTY ROAD 5 S CENTENNIAL DR GREGORY RD GIDDINGS RD W LAUREL ST KECHTER RD S US HIGHWAY 287 E COUNTY ROAD 54 E COUNTY ROAD 52 / Fort Collins Area Water Districts 012345 0.5 Miles Water Districts East Larimer County Water District Fort Collins Loveland Water District Fort Collins Utilities (Water) Sunset Water District West Fort Collins Water District !!City Limits GMA Major Streets Railroads Figure Updated: 9/23/2015 ATTACHMENT 1