HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 04/21/2020 - SECOND READING OF ORDINANCE NO. 053, 2020, AMENDINAgenda Item 11
Item # 11 Page 1
AGENDA ITEM SUMMARY April 21, 2020
City Council
STAFF
Mariel Miller, Water Conservation Specialist
Lisa Rosintoski, Utilities Deputy Director, Customer Connections
Donnie Dustin, Water Resources Manager
Liesel Hans, Water Conservation Manager
Eric Potyondy, Legal
SUBJECT
Second Reading of Ordinance No. 053, 2020, Amending Chapter 26 of the Code of the City of Fort Collins to
Adopt a Water Shortage Action Plan (Previously Known as the Water Supply Shortage Response Plan) and
Making Various Related Changes.
EXECUTIVE SUMMARY
This Second Reading is necessary to continue the public process and ensure the updated Water Shortage
Action Plan can be utilized when responding to future water shortages.
This Ordinance, unanimously adopted on First Reading on April 7, 2020, adopts into City Code by reference
an updated Water Supply Shortage Response Plan (WSSRP) for Fort Collins Utilities. The updated plan and
updates to City Code Section 26-167(a) include: changing the name to the Water Shortage Action Plan
(WSAP); adding new sections to the Plan; changes and additions to various restrictions; changes to the
structure of the water restriction levels; and changes to the water rate increases during declared water
shortages.
STAFF RECOMMENDATION
Staff recommends adoption of the Ordinance on Second Reading.
ATTACHMENTS
1. First Reading Agenda Item Summary, April 7, 2020 (w/o attachments) (PDF)
2. Ordinance No. 053, 2020 (PDF)
Agenda Item 18
Item # 18 Page 1
AGENDA ITEM SUMMARY April 7, 2020
City Council
STAFF
Mariel Miller, Water Conservation Specialist
Lisa Rosintoski, Utilities Deputy Director, Customer Connections
Donnie Dustin, Water Resources Manager
Liesel Hans, Water Conservation Manager
Eric Potyondy, Legal
SUBJECT
Public Hearing and First Reading of Ordinance No. 053, 2020, Amending Chapter 26 of the Code of the City of
Fort Collins to Adopt a Water Shortage Action Plan (Previously Known as the Water Supply Shortage
Response Plan) and Making Various Related Changes.
EXECUTIVE SUMMARY
The purpose of this item is to adopt into City Code by reference an updated Water Supply Shortage Response
Plan (WSSRP) for Fort Collins Utilities. The updated plan and updates to City Code Section 26-167(a) include:
changing the name to the Water Shortage Action Plan (WSAP); adding new sections to the Plan; changes and
additions to various restrictions; changes to the structure of the water restriction levels; and changes to the water
rate increases during declared water shortages.
STAFF RECOMMENDATION
Staff recommends adoption of the Ordinance on First Reading.
BACKGROUND / DISCUSSION
It has been seven years since the last water shortage (2013) and six years since the last update to the WSSRP
(Ordinance No. 088, 2014). Staff has prepared an updated Plan for consideration that reflects a broader range
of input than ever before, incorporates best practices from the Colorado Water Conservation Board (CWCB),
and prepares for water shortage scenarios that are missing from the current Plan. Having and managing a water
shortage plan is required by the current Water Supply and Demand Management Policy (2012).
The main objectives of this update are:
Share and remind City staff and Utilities customers what a water shortage is and that the City has a response
plan that requires water restrictions.
Identify beneficial changes.
Improve overall resiliency and preparation for the next water shortage.
History
Water shortages are a part of life in the arid west; however, like most of Colorado, Fort Collins Utilities did not
have a formal provision in City Code or plan in place until 2002. In 2002, Fort Collins and much of Colorado
experienced a severe drought, which extended into 2003, and provided the impetus to develop a plan. The first
plan was adopted in July 2002 (Ordinance No. 112, 2002) and initially only restricted lawn watering. It was
revised multiple times over the course of the 2002-2003 drought and was eventually replaced in April 2003
ATTACHMENT 1
Agenda Item 18
Item # 18 Page 2
(Ordinance No. 048, 2003) with a more comprehensive response plan. The most recent water shortage was a
result of water quality and quantity issues that necessitated the declaration of a Level I water shortage response
for two months - April 1, 2013, to June 1, 2013. After this experience with restrictions, a few updates were made
to what exists today, Ordinance No. 088, 2014. (Attachment 1)
What is a Water Shortage Action Plan?
A water shortage occurs when the projected water supply is less than the anticipated water demand, with
consideration of water reserves in storage or other criteria, as defined by the Water Supply and Demand
Management Policy. The following events, or combination of events, are examples that could cause a water
shortage:
Drought
Water quality issues, such as contamination or fire
Infrastructure issues, such as pipeline or water treatment facility issues
Given the variability in water shortage causes and impacts, a water shortage action plan requires an analytical
approach that allows for flexibility to address the given shortage, as well as projected shortages that may be
anticipated. The WSAP establishes flexible options with guidance and transparency (the new WSAP is Exhibit
B to Ordinance NO. 053, 2020).
The existing WSSRP outlines four different response levels with corresponding water use restrictions, water rate
increases, and simple information about violations and the water shortage declaration process (Attachment 1).
The process for declaring a water shortage is:
1. Water Shortage Indicators (Section 1.4 of Exhibit B) and other necessary information is analyzed by
Utilities and presented to the Action Committee (Section 1.6 of Exhibit B).
2. The Action Committee develops a recommendation with supporting data, description of the evaluation,
and the proposed response.
a. If Action Level IV is recommended, additional information should be provided to the City
Manager that includes a description of which restriction(s) are recommended from the Action
Summary Table (Section 1.2 of Exhibit B) and why; or in the case of an extreme water shortage,
which types of indoor water uses will be rationed and to what degree or extent.
3. The recommendation is presented to the City Manager.
4. The City Manager considers the Action Committee’s recommendation to determine whether to declare
a water shortage and, if so, which action level to select.
a. If Action Level IV is selected, the City Manager must include a description in the declaration of
which restriction(s) are selected from the Action Summary Table; or in the case of an extreme
water shortage, which types of indoor water uses will be rationed and to what degree or extent.
When possible, City Council will be informed in advance of the water shortage declaration. A water shortage
declaration may need to be made quickly, in order to minimize the severity of the shortage. In these instances,
City Council will be notified as quickly as possible following the water shortage declaration. After the declaration
of a water shortage, the City Manager shall issue a declaration and order pursuant to City Code 26-167(a), in
conjunction with the City Attorney’s Office and City Clerk.
Update Process
Starting in early 2019, staff researched other communities’ plans, consulted with the CWCB, and engaged the
community as well as City and Utilities staff. Research and public engagement led to development of the guiding
principles, which were then used to review the existing Plan’s approach and identify updates that better align the
Plan with the community’s water use priorities. More information is included in the Public Outreach section and
Attachment 4.
Proposed Water Shortage Action Plan (WSAP) Updates
Agenda Item 18
Item # 18 Page 3
Proposed changes have been informed by engagement efforts, recommendations from the CWCB, and research
across Colorado’s Front Range and other western states’ utilities and communities. The following title change
and added plan elements provide a more comprehensive water shortage response, in contrast to the previous
WSSRP, which primarily consisted of a response summary table. These changes include, but are not limited to,
the following. (See Attachment 2 for additional changes and more details.)
Changes to the Action Summary Table (Section 1.2 of Exhibit B), such as:
o Consolidation of previous levels to simplify and better reflect realistic water use reductions.
o Addition of a voluntary “Water Shortage Watch” level to reflect best practices.
o Addition of an Alternative level to allow Utilities to be prepared for and respond to unique or
extreme water shortages, like those that may occur during winters months or a shortage due to
a planned or unplanned infrastructure outage.
Change to the Plan’s title; change from “Water Supply Shortage Response Plan” to “Water Shortage Action
Plan,” to reflect that shortages may stem from a water quality or infrastructure issue, in addition to a water
quantity issue.
Added Plan elements, such as:
o Guiding principles, which incorporate the community’s water use priorities, as well as other best
practices.
o Explanation of the water shortage indicators, which establish criteria used to evaluate a water
shortage and inform the selection of an action level.
o Other response strategies, such as short-term water supply options to compliment the water
use restrictions.
o Creation of an Action Committee who would review the water shortage indicator analyses and
other relevant information and propose a water shortage declaration recommendation to the
City Manager.
o Communication and engagement plan to utilize before or during a water shortage.
o WSAP update cycle and process for community review and engagement. Establishes a
regular update cycle of 5 years or less.
o Recommendations to be pursued in future updates, depending on resources and feasibility.
Connections and Next Steps
Utilities staff recently completed a Water Supply Vulnerability Study. This highlighted the need to re-evaluate
water supply and demand planning to reflect a variety of future scenarios and the impacts of increased variability
due to climate change impacts. The study indicated that the City may need to enact water restrictions more
frequently than in the past without additional water supplies and/or water conservation. The information from this
Study will be incorporated in the update of the Water Supply and Demand Management Policy, which is being
updated over the next couple of years. After that point, there may be new Utilities water planning criteria and
level of service goals that could prompt and inform an update to the WSAP.
The WSAP update process highlighted areas to explore, such as greater regional water shortage collaboration
and identification and development of short-term supplies, as part of the next Plan update process but were
beyond the scope of this project. Further evaluation of these opportunities is expected within the next update
cycle. Additional funding and support for future enhancements to the Plan will be explored.
The CWCB provides technical assistance and grant funding for water shortage planning and implementation. In
order to be eligible for grant funding, water providers must submit adopted and final plans to CWCB for a formal
review process. The WSAP has received a preliminary review from CWCB and Utilities Staff will submit for a
formal review, if it is adopted by City Council.
Strategic Alignment
The WSAP is aligned with numerous City plans and policies, as well as supported by the State of Colorado.
Agenda Item 18
Item # 18 Page 4
City Strategic Plan (2018)
Environmental Health
o 4.5 Develop strategies to improve the community’s climate resiliency
o 4.6 Provide a reliable, high-quality water supply
Safe Community
o 5.1 Improve community involvement, education and regional partnerships to increase the level
of public trust and keep the community safe
High Performing Government
o 7.1 Provide world-class municipal services to residents and businesses
o 7.3 Promote a values-driven organizational culture that maintains the public trust through ethical
behavior and transparency
o 7.6 Leverage data, technology, metrics and benchmarks to guide decisions, improve results and
enhance service delivery
City Plan (2019)
Policy ENV 2.2 - Integrate Mitigation and Resilience Actions
Policy ENV 6.1 - Water Resource Planning
Policy ENV 6.3 - Droughts and Vulnerability
Policy HI 1.4 - Continuous Improvement in Service
Water Supply and Demand Management Policy (2012)
Water Supply and Demand Management Policy (Policy), which provides a foundational framework for water
supply and demand management decisions concerning the City’s water supply system. Per the current
Policy, the City plans to have water supplies that can meet demands through a 1- in-50 year drought without
mandatory restrictions. As stated in Section 2.3 of the Policy, for more extreme droughts or during
emergencies, a plan to respond to these situations shall be developed and maintained.
State of Colorado Water Conservation Board
Colorado Drought Mitigation and Response Plan (2018) identifies drought as a key hazard and incorporates
the importance of drought planning at a local level into the State Plan.
State Code Section 37-60-126.5, Drought Mitigation Planning; authorizing the CWCB to support local
planning effort with State assistance.
CITY FINANCIAL IMPACTS
Utilities’ revenue is expected to be reduced during a water shortage due to reduced water consumption from
water use restrictions. Staff evaluated the existing water rate increases in the current WSSRP and adjusted rate
increases in the proposed WSAP to reflect updated revenue recovery estimations (Section 1.2 of Exhibit B). The
proposed volumetric rate increases, 20% at Action Level II and 30% at Action Level III, are estimated to
adequately recover lost revenue while providing no cost increase to customers who reduce their consumption
by the estimated amount expected during a water shortage at the corresponding Action Levels. For example,
the average bill impact for a single-family residential customer or commercial customer in a year with Action
Level II restrictions, would result in a savings of $6.60 and $23.00, respectively, if use was reduced by the
expected 20%.
Additional financial resources may be needed for implementation and enforcement during a water shortage. It’s
expected that those additional resources needed will come from Utilities enterprise fund.
BOARD / COMMISSION RECOMMENDATION
Agenda Item 18
Item # 18 Page 5
At its February 20, 2020 meeting, the Water Board unanimously recommend approval of the updates to the
Water Supply Shortage Response Plan. (Attachment 3)
PUBLIC OUTREACH
Around 800 people were engaged at 65 different meetings and presentations, plus hundreds of others across
larger community-scale events. A main objective of the project was to inform and remind City and Utilities staff,
City boards and commissions, customers and stakeholders that when water shortages occur, the City has a
plan, as well as identify potential beneficial changes. Many City departments had not previously been involved
in planning for water shortages and the proposed Plan includes several updates that would not have been
identified without these conversations and partnerships. Staff utilized engagement efforts, like focus groups and
surveys, to better understand broad and restriction-specific challenges and beneficial changes that might
address these challenges. The engagement activities included numerous interactive feedback and data
gathering tactics that provided quantitative and qualitative outcomes. For example, a voting activity was designed
to quickly and easily gather public input on how to prioritize water use during shortages. This activity was used
at several events during the public engagement phase. The community’s feedback from this activity helped
develop the framework for the Plan’s guiding principles and provided a lens for evaluating water use restrictions.
(Attachment 4)
Cross-Departmental Partnerships
During the engagement effort, numerous opportunities for greater partnership and collaboration between Water
Conservation and others developed. The following highlight some of these cross-departmental partnerships
within the City organization:
Code Compliance has agreed to assist in enforcement efforts during water shortages, which is a great
improvement from what has previously been complaint-based enforcement done solely by Water
Conservation due to limited Staff.
Environmental Regulatory Affairs and Environmental Services worked with Water Conservation to
develop the dust control restrictions and ensure they’re aligned with other City Codes and supported by the
Dust Control and Prevention Manual.
Parks and Golf have stated that they would follow the water use restrictions on all parks and golf courses,
regardless of whether they’re on raw water or the City’s treated water. Most of these facilities are irrigated
with raw water (exempt from water use restrictions), which can cause public perception challenges when not
following restrictions or do not have park related watering permits.
Streets helped develop the street sweeping water use restrictions and agreed to modify their street
sweeping schedule during a water shortage to accommodate lesser water use, but still allow for essential
street sweeping needed to maintain health and safety.
Emergency Preparedness and Security (EPS) provided valuable input for the WSAP - connecting it to
other emergency planning efforts and providing input on the structure of the summary table. EPS would
participate on the water shortage response committee to provide emergency planning expertise and allow
for continuity if a water shortage were to ever evolve into a scenario that necessitated an emergency
response.
Other Water Districts
Staff met with East Larimer County and Fort Collins-Loveland Water Districts during the Plan’s review and
update. Staff identified the benefits of having an aligned and unified action plan but realized there are many
challenges that make it difficult to collaborate during a water shortage, such as differing water portfolios,
resources, and other considerations which are not aligned well between Utilities and the districts.
Staff identified that there may be opportunities for collaboration, depending on the water shortage scenario.
Discussions with districts prior to and during a water shortage, will help identify these opportunities. WSAP has
included the following processes and highlighted these coordination points within the document, to help better
facilitate the potential for district partnerships.
Agenda Item 18
Item # 18 Page 6
Stakeholder Committee (Section 1.6 of Exhibit B)-water districts are listed entities on this committee to
provide continuity between the districts and throughout a water shortage; and allow for early collaboration
opportunities.
Communication and Engagement Plan (Appendix A of Exhibit B)-water districts are named within the plan
and identified as potential communication partners.
Future WSAP updates (Section 4.3 of Exhibit B)-regional water shortage approach is identified as a future
update that would take time and commitments to develop but could provide important benefits to water
providers and customers.
ATTACHMENTS
1. Current Plan (WSSRP) (PDF)
2. Summary of WSAP Updates (PDF)
3. Engagement Summary (PDF)
4. Memo to Council March 11, 2019 (PDF)
5. Memo to Council December 5, 2019 (PDF)
6. Water Board Meeting Minutes Feb 20 2020 (PDF)
7. Powerpoint presentation (PDF)
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ORDINANCE NO. 053, 2020
OF THE COUNCIL OF THE CITY OF FORT COLLINS
AMENDING CHAPTER 26 OF THE CODE OF THE CITY OF
FORT COLLINS TO ADOPT A WATER SHORTAGE ACTION PLAN
(PREVIOUSLY KNOWN AS THE WATER SUPPLY SHORTAGE
RESPONSE PLAN) AND MAKING VARIOUS RELATED CHANGES
WHEREAS, the City owns and operates Fort Collins Utilities, which includes a water
utility (“Water Utility”), as described in Article III of Chapter 26 of the Code of the City of Fort
Collins (“City Code”); and
WHEREAS, the Water Utility, among other things, provides treated water service to
customers in its water service area; and
WHEREAS, City Code Section 26-167(a) concerns the Water Utility’s water supply
shortage response and contemplates the City’s adoption of a Water Supply Shortage Response
Plan (to be renamed through this ordinance as a “Water Shortage Action Plan”) to establish
conditions and restrictions to be used by the City Manager to manage the City’s water supply in
the event of projected shortages in supply; and
WHEREAS, pursuant to City Charter, Article II, Section 7, City Council may enact any
ordinance which adopts any code by reference in whole or in part provided that before adoption of
such ordinance the Council shall hold a public hearing thereon and notice of the hearing shall be
published twice in the newspaper of general circulation, published in the city, one (1) of such
publications to be at least eight (8) days preceding the hearing and the other at least fifteen (15)
days preceding the hearing; and
WHEREAS, in compliance with City Charter, Article II, Section 7, the City Clerk
published in the Fort Collins Coloradoan such notice of hearing on March 22, 2020, and March
29, 2020; and
WHEREAS, the attached Exhibit “A” is a copy of the text of the Notice of Public Hearing
that was so published and which the Council hereby finds meets the requirements of City Charter,
Article II, Section 7; and
WHEREAS, pursuant to City Code Section 1-14, at least one copy of the Water Shortage
Action Plan shall be kept on file in the office of the City Clerk available for public inspection, and
one copy shall be kept in the office of the Utilities Executive Director; and
WHEREAS, City Code Section 26-168 states that any person who violates any provision
of Division 6 of Article III of Chapter 26 of City Code commits a civil infraction and shall be
subject to the provisions of City Code Section 1-15, as modified by the Water Shortage Action
Plan, and that each day that a prohibited conditioned is maintained shall constitute a separate
offense; and
-2-
WHEREAS, the Water Board has recommended adoption of the Water Shortage Action
Plan; and
WHEREAS, the City Manager and City staff have recommended to the City Council that
the Water Shortage Action Plan be adopted by reference and that the following changes be made.
NOW, THEREFORE, BE IT ORDAINED BY THE COUNCIL OF THE CITY OF FORT
COLLINS as follows:
Section 1. That the City Council hereby makes and adopts the determinations and
findings contained in the recitals set forth above.
Section 2. That all current and previous versions of the Water Supply Shortage
Response Plan including, but not limited to, those adopted by Ordinance No. 048, 2003, Ordinance
No. 047, 2013, and Ordinance No. 088, 2014, are repealed in their entirety.
Section 3. That Section 26-167 of the Code of the City of Fort Collins is hereby
amended to read as follows:
Sec. 26-167. - Water supply shortage response; emergency restrictions.
(a) Water supply shortage. Pursuant to the authority conferred by Article II, Section 7 of
the Charter, there is hereby adopted by reference the Water Shortage Action Plan, dated
April 2020, as the plan to establish conditions and restrictions to be used by the City
Manager to manage the water utility’s water supply in the event of projected shortages in
supply, which shall have the same force and effect as though set forth herein. One (1) copy
of the Water Shortage Action Plan shall be kept on file in the office of the City Clerk and
available for public inspection during regular business hours. In the event the City
Manager determines, pursuant to the Water Shortage Action Plan, that restrictions on the
use of water by water utility customers are necessary in order to manage the availability of
water for use in the immediate future or within the planning horizon for managing the water
utility’s water supply, the City Manager may determine the applicable water supply
shortage response level and declare as applicable the associated water use restrictions, as
set forth in the Water Shortage Action Plan. The City Manager’s declaration and order
prescribing use restrictions shall be effective on the date specified in such order. The City
Manager shall cause publication of any such order no less than once in a daily newspaper
published in Fort Collins on or prior to the effective date. Such order of the City Manager
shall continue in full force and effect until the City Manager has determined that the water
supply shortage response level has changed or that the projected water supply shortage has
ended, and a determination and order to that effect has been published in the same manner
as for an initial declaration.
. . .
Section 4. That Section 26-168 of the Code of the City of Fort Collins is hereby
amended to read as follows:
-3-
Sec. 26-168. - Obligation to comply; penalties.
. . .
(c) Violation of plan or permit. No person shall violate the restrictions or requirements of
any Water Shortage Action Plan provision or emergency restriction that the City Manager
has ordered into effect in accordance with this Section, or any permit issued thereunder.
(d) Civil infraction. Any person found guilty of violating any provision of this Division
or any restriction or requirement imposed pursuant to this Division, whether by acting in a
manner declared to be unlawful or failing to act as required, commits a civil infraction and
shall be subject to the penalty provisions of Subsection 1-15(f) of this Code, except that,
notwithstanding the provisions of Subsection 1-15(f), fines for violations of a Water
Shortage Action Plan restriction or requirement imposed pursuant to this Division shall be
as set forth in said Plan as adopted.
. . .
Section 5. That the Water Shortage Action Plan dated April 2020, which is on file with
the City Clerk and also attached hereto as Exhibit “B” is hereby approved and adopted by
reference.
Introduced, considered favorably on first reading, and ordered published this 7th day of
April, A.D. 2020, and to be presented for final passage on the 21st day of April, A.D. 2020.
__________________________________
Mayor
ATTEST:
_______________________________
City Clerk
Passed and adopted on final reading on the 21st day of April, A.D. 2020.
__________________________________
Mayor
ATTEST:
_______________________________
City Clerk
NOTICE OF PUBLIC HEARING
NOTICE is hereby given of a public hearing to be held before the City Council of the City
of Fort Collins, Colorado, on the 7th day of April, A.D., 2020 at 6:00 p.m., or as soon thereafter as
the matter may come on for hearing, in the Council Chambers at the City Hall, 300 LaPorte
Avenue, Fort Collins, Colorado for the purpose of considering an ordinance adopting by reference
the Water Shortage Action Plan, dated April 2020, prepared by City of Fort Collins staff.
Not less than one (1) copy of said Plan has been, and now is on file in the Office of the
City Clerk of the City of Fort Collins and is available for public inspection.
The purpose of the Water Shortage Action Plan, dated April 2020, adopted by said
ordinance is to establish conditions and restrictions to be used by the City Manager to manage the
water utility’s water supply in the event of projected shortages in supply. In the event the City
Manager determines, pursuant to the Plan, that restrictions on the use of water by water utility
customers are necessary in order to manage the availability of water for use in the immediate future
or within the planning horizon for managing the water utility’s water supply, the City Manager
may determine the applicable water supply shortage response level and declare as applicable the
associated water use restrictions, as set forth in the Plan.
The City of Fort Collins will make reasonable accommodations for access to City services,
programs and activities and will make special communication arrangements for persons with
disabilities. Please call 221-6515 (V/TDD: Dial 711 for Relay Colorado) for assistance.
This notice is given and published by order of the City of Fort Collins, Colorado.
Dated at Fort Collins, Colorado this 22nd day of March, A.D. 2020.
Delynn Coldiron
City Clerk
EXHIBIT A
As adopted by the City Council of the City of Fort Collins,
April 2020, as referenced in Section 26-167(a) of the
Code of the City of Fort Collins
As adopted by Fort Collins City Council April 2020,
as referenced in Section 26-167(a) of the
Code of the City of Fort Collins
Water Shortage Action Plan
April 2020
EXHIBIT B
Fort Collins Utilities ii 2020 Water Shortage Action Plan (WSAP)
Contents
Glossary ..................................................................................................... 4
Chapter 1 Water Restrictions ................................................................... 8
1.1 Guiding Principles .................................................................................................. 8
1.2 Action Summary Table ......................................................................................... 9
1.3 Declaring a Water Shortage .............................................................................. 19
Moving Between Levels and Returning to Normal Conditions ........................ 19
1.4 Water Shortage Indicators ................................................................................. 19
Water Supply Operations Model .......................................................................... 22
1.5 Other Response Strategies ................................................................................ 23
1.6 Responding to a Water Shortage ...................................................................... 23
Implementation ....................................................................................................... 23
Monitoring ................................................................................................................ 24
Water Shortage Committees ................................................................................ 24
Chapter 2 Permits .................................................................................... 25
2.1 Types of Permits .................................................................................................. 25
New Seed or Sod Permit....................................................................................... 26
Medical/Physical Hardship .................................................................................... 26
Religious Objection Permit ................................................................................... 26
Large (Four Acres or Greater) and City Parks Inactive Areas Permit ........... 27
City and Community Active Areas Permit .......................................................... 27
Well or Raw Water Sources ................................................................................. 27
2.2 Permit Application and Process ........................................................................ 28
Permit Approval Process – New and Renewal Applications ........................... 28
Signage .................................................................................................................... 29
Permits and Changing Action Levels .................................................................. 29
Chapter 3 Enforcement ........................................................................... 29
3.1 Need for Additional Resources .......................................................................... 29
3.2 Fines for Violations .............................................................................................. 29
3.3 Enforcement Guidelines ..................................................................................... 30
Business and Residential Violations ................................................................... 30
Methods of Enforcement ....................................................................................... 30
EXHIBIT B
Fort Collins Utilities iii 2020 Water Shortage Action Plan (WSAP)
Educational Resources ......................................................................................... 30
Reporting Complaints ............................................................................................ 31
3.4 Turning Off Water ................................................................................................ 31
Chapter 4 WSAP Updates ....................................................................... 31
4.1 WSAP Review ...................................................................................................... 31
4.2 Public Review Process ....................................................................................... 31
4.3 Updates ................................................................................................................. 33
Appendix A Communication and Engagement Plan ........................... 35
Appendix B Relation to Other Plans and Policies ............................... 43
Appendix C Historical Shortage Planning and Events ........................ 45
Appendix D Profile of Existing System ................................................. 50
Appendix E Water Supply Vulnerability Assessment .......................... 55
EXHIBIT B
Fort Collins Utilities 4 2020 Water Shortage Action Plan (WSAP)
Glossary
Action Summary Table shall mean the table included as part of this WSAP that
summarizes the various action levels and associated water use restrictions that are
associated with different projected water shortages. This table is a key aspect of WSAP
and shall be used by the City and City Manager when implementing this the WSAP and
when imposing any restrictions on the use of water by water utility customers pursuant to
City Code 26-167(a).
Active area shall mean a property or portion of a property that is used for athletics or
playing field by an organization for routine and frequent use, including a golf course’s
fairways.
Arterial street shall mean high capacity, urban road that moves traffic to collectors and
other arterial streets.
Call shall mean when a water user with a senior water right, forces upstream water
users with junior water rights to let sufficient water flow in the river to meet the
requirements of the senior water right. Calls are administered by the Colorado Division
of Water Resources.
CBT shall mean the Colorado-Big Thompson Project (managed by Northern Water).
Utilities receives CBT water from Horsetooth Reservoir. The amount of water allotted to
each CBT contractual unit is referred to as CBT quota.
Collector street shall mean low to medium capacity road that moves traffic to local and
arterial streets.
Commercial shall mean business, industrial, or institutional premises, and shall include
sprinkler-only taps that are used solely for irrigation on these premises, and homeowner
associations’ common areas.
Community outdoor swimming pool shall mean an outdoor structure that is filled with
water and used for swimming and includes all in-ground pools, above-ground pools, and
pools owned by an HOA, the City of Fort Collins, or any other entity; that are not for
personal use and are accessible to the public or many people.
Dealership vehicle shall mean any unregistered vehicle on display or awaiting sale by a
vehicle dealer or other person holding or selling vehicles in the normal course of
business.
Drip system shall mean a low-pressure, low-volume irrigation system, above or below
ground, that delivers water to the root zone of plant material through emitters or porous
material at a low pressure. Drip system includes bubblers, drip emitters, in-line tubing,
subsurface irrigation, or soaker hoses. Drip system excludes micro-sprays.
Dust control measures shall mean any actions or processes that are used to prevent
or mitigate the emission of fugitive dust into the air, including, but not limited to, the
best management practices identified in the Dust Prevention and Control Manual
(DPCM), as adopted under City Code Section 12-152. For the purposes of the WSAP,
the dust control measures referenced shall be limited to those that require the use of
water as defined in the DCPM, specifically on-tool wet suppression and wet suppression.
Dust generating activities or sources shall mean processes, operations, actions or
land uses that create emissions of fugitive dust or cause off-property or off-vehicle
transport, as described in more detail in the DPCM.
EXHIBIT B
Fort Collins Utilities 5 2020 Water Shortage Action Plan (WSAP)
Essential power washing shall mean cleaning with high-pressure, low-volume water or
steam in an outdoor location or in a manner that discharges flows to the outdoors, in
accordance with any applicable stormwater regulations and City Code Section 26-498,
for health and safety reasons, graffiti abatement, surface preparation for the application
of architectural coatings, or painting or cleaning of heating, ventilation and air
conditioning equipment.
Essential street sweeping shall mean cleaning of paved right-of-way surfaces by the
City or others, with equipment that uses water in accordance with any applicable
stormwater regulations, including City Code Section 26-498, and DPCM for health,
safety and environmental cleanup reasons.
Food production shall mean the application of water to vegetables, fruits, or herbs to
be used as a source of food. Food production shall not mean landscape or lawn
watering, watering of trees not used for food production, or watering with well or raw
water.
Fugitive dust shall mean solid particulate matter emitted into the air by mechanical
processes or natural forces but is not emitted through a stack, chimney, or vent.
Hand watering shall mean the application of water to plant material while holding a
hose in hand that has a positive shut-off nozzle. Hand watering shall not mean watering
with a sprinkler on the end of a hose.
Health and safety reasons shall mean reasons reasonably necessary to remedy an
unsanitary or dangerous condition that poses a health or safety risk or danger to the
public or to the occupants of a particular property.
Horsetooth shall mean Horsetooth Reservoir, which is part of the CBT system.
HOA shall mean a homeowners’ association, or similar organization.
Inactive area shall mean a property or portion of a property that is not used for athletics
or other playing fields by an organization for routine and frequent use, including the
rough area of a golf course.
Individual outdoor swimming pool shall mean an outdoor structure that is filled with
water and used for swimming and includes all in-ground pools, above-ground pools, and
pools owned by an individual for personal use and not accessible to the public or many
people.
Landscape watering shall mean the use of treated or potable water obtained from
Utilities to irrigate any lawn, tree, food production, flowers, shrubs, or other landscape
plantings or plants. Landscape watering shall not mean watering with well or raw
water.
Lawn shall mean the use of treated or potable water obtained from Utilities to irrigate or
water any lawn, grass, or turf areas, including regionally adapted species. Lawn
watering shall not mean food production, non-lawn landscape, trees, or watering with
well or raw water.
Local street shall mean a low capacity road that is not a collector or arterial street. A
local street can be a private or public right-of-way.
Medical hardship shall mean an exceptional hardship imposed upon an individual
residential customer because of medical reasons by the restrictions set forth in the
WSAP.
EXHIBIT B
Fort Collins Utilities 6 2020 Water Shortage Action Plan (WSAP)
Misting device shall mean an evaporative cooling system, forcing water through small
nozzles to create a fine mist or fog outdoors.
Multifamily shall mean residential premises that have more than two units and shall
include sprinkler only taps that are used solely for irrigation on these premises.
Other landscape shall mean the use of treated or potable water obtained from Utilities
to irrigate any flowers, shrubs, or other landscape plantings or plants. Other landscape
shall not mean food production, lawn or tree, or watering with well or raw water.
Northern Water shall mean the Northern Colorado Water Conservancy District.
Platte River shall mean the Platte River Power Authority.
Poudre River shall mean Cache la Poudre River.
Recreation water toy shall mean an outdoor toy used on a private premise that requires
water to operate and typically uses continuous water from a hose.
Regionally adapted species shall mean plants originally native to Colorado or other
regions of the world that are acclimated to average temperatures and precipitation found
in Fort Collins and are able to survive with little-to-no supplemental irrigation required
following establishment.
Religious objection shall mean an objection to the specific application of the
requirements of the WSAP due to a conflicting religious belief that precludes watering on
an assigned day.
Residential shall mean a single-family or duplex residential premise.
Residential vehicle washing shall mean washing a vehicle on a residential premise in
compliance with any applicable stormwater regulations and City Code Section 26-498.
Splash park shall mean an interactive water structure in a public space intended for
public use and play and managed in accordance with applicable water quality
requirements.
Spraying impervious surfaces shall mean rinsing, washing, or spraying with water or
steam an impervious interior or exterior surface, including, but not limited to, surfaces
such as garage floors, siding, windows, sidewalks, driveways, or patios, that will
discharge flows outdoors in accordance with any applicable stormwater regulations and
City Code Section 26-498.
Sprinkler shall mean an automated or manual system or a piece of equipment added to
a hose that is used to spray water into the air so that droplets fall to the ground, including
micro-sprays.
Sprinkler system maintenance shall mean the operation of a sprinkler system to the
extent reasonably necessary for repair or maintenance, as long as a person is on site all
times and testing is limited to verifying proper operation and identifying problems.
Tree shall mean a woody plant, typically having a single stem or trunk growing to a
considerable height and bearing lateral branches elevated from the ground.
Utilities shall mean Fort Collins Utilities, which is owned and operated by the City of Fort
Collins, a home rule municipality.
Water feature shall mean a device that creates a waterfall or fountain intended only for
aesthetic purposes. Water feature shall not mean a water feature with a pond or basin
EXHIBIT B
Fort Collins Utilities 7 2020 Water Shortage Action Plan (WSAP)
that performs a function essential to the support of fish life in that pond or basin or a
water feature in a swimming pool or a splash park.
Windy Gap shall mean the Windy Gap Project, owned by Northern Water.
Well or raw water shall mean water from a well or other untreated (raw) water source,
such as a well, ditch, or reservoir.
WSAP shall mean this Water Shortage Action Plan under City Code Section 26-167(a).
WEP shall mean Water Efficiency Plan, a plan adopted by the City Council to address
long-term water conservation and efficiency planning, administered by Utilities’ Water
Conservation Division.
WRD shall mean Utilities’ Water Resources Division.
EXHIBIT B
Fort Collins Utilities 8 2020 Water Shortage Action Plan (WSAP)
Chapter 1 Water Restrictions
The Water Shortage Action Plan (WSAP), previously known as the Water Supply
Shortage Response Plan, establishes conditions and restrictions to manage Utilities
water supply in the event of projected shortages as established by City Code Section 26-
167(a).
A water shortage occurs when the projected water supply is less than the anticipated
water demand, with consideration of water reserves in storage or other criteria, as
defined by the Water Supply and Demand Management Policy. The following events, or
combination of events, are examples that could cause a water shortage:
• Drought
• Water quality issues, such as contamination or fire
• Infrastructure issues, such as pipeline or water treatment facility issues
Given the variability in water shortage causes and impacts, a water shortage action plan
requires an analytical approach that allows for flexibility to address the given shortage,
as well as projected shortages that may be anticipated. The WSAP establishes flexible
options with guidance and transparency.
1.1 Guiding Principles
An effective response to water shortage requires a suite of strategies and tactics – no
single water restriction will provide the response needed for most water shortages. The
following guiding principles, not listed in order of priority or importance, will be followed
as possible during a shortage.
Restrict less-essential uses first and avoid restrictions on more essential uses.
• Minimize restrictions on indoor water use for commercial and residential
customers and uses that preserve health and safety.
Minimize adverse economic impacts.
• Minimize impacts to water-based businesses.
• Work with stakeholder businesses, such as those in the landscape industry.
Protect public and community activities.
• Minimize impacts to resources such as City parks, heavily used landscapes, and
other public and community resources.
• Preserve public and community pools and splash parks during less severe water
shortages.
Implement extensive public information and media relations program.
• Inform customers and stakeholders early and update regularly.
• Maintain transparency and trust through accurate and consistent messaging and
communication.
• Leverage community partnerships for information dissemination.
EXHIBIT B
Fort Collins Utilities 9 2020 Water Shortage Action Plan (WSAP)
Avoid irretrievable loss of natural vegetation.
• Minimize impacts to food production, such as vegetable gardens and trees, and
perennial landscapes.
• Promote alternative, water-efficient irrigation methods, such as drip or hand-
watering.
Explore alternative water supply options.
• Evaluate options to potentially increase water supplies and pursue when
necessary and/or cost-effective relative to demand measures.
Collaborate regionally and with other water service providers.
• Involve adjacent water districts in water shortage action planning and
implementation, where applicable.
• Communicate with adjacent water districts early and throughout water shortage.
• Engage in regional water shortage discussions, seeking regional collaboration
and solutions when practical.
1.2 Action Summary Table
Pursuant to City Code Section 26-167(a) and this WSAP, the City Manager determines
whether water use restrictions are necessary to manage the availability of water for use
in the immediate future or within the planning horizon for managing the water utility’s
water supply. If the City Manager makes this determination, then a water supply
shortage action level and the associated water use restrictions as applicable, is
declared, as set forth in the WSAP.
The following Action Summary Table summarizes the action levels and associated water
use restrictions. In a declared water shortage, the table shall be used by the City and the
City Manager when implementing this WSAP and when imposing restrictions on the use
of water by water utility customers pursuant to City Code 26-167(a).
There are three types of demand reduction strategies in the Action Summary Table on
page 11.
Voluntary indoor water use strategies encourage optional and additional water use
reductions based on water-efficient best practices and will be promoted concurrently
during any mandatory outdoor water use restrictions. In addition, the Water Shortage
Watch Action Level involves voluntary restrictions, which are based on Level I
mandatory actions or best practices and will promote awareness while staff is continuing
to monitor the given situation. These actions may provide for water shortage mitigation
and avoid or defer mandatory restrictions.
Mandatory outdoor water use restrictions are required water use reduction strategies
that are subject to monitoring and enforcement.
Alternative demand reduction actions may include a unique combination of mandatory
restrictions and/or voluntary water use reductions. This level should be enacted when
other Action Levels outlined in the WSAP are not adequate or appropriate to address a
EXHIBIT B
Fort Collins Utilities 10 2020 Water Shortage Action Plan (WSAP)
unique or extreme water shortage scenario. The declaration of Action Level IV, includes,
but is not limited to, the following water shortage scenarios:
• Non-irrigation season water shortages
• Extreme water shortages projected in excess of 35%
Action Level IV includes the ability to select restrictions and exceptions by permit, as
outlined in the other Action Level’s outlined in the Action Summary Table and may
require indoor rationing or other restrictions to address given water shortage projections
when outdoor or other non-essential restrictions alone will not suffice or meet the needs
of the situation.
Temporary Rate Increase
Rate increases apply to the rate schedule in place at that time of Action Levels II and III.
Rate increase for Level IV, or otherwise undefined in the Action Summary Table, may
require approval from Council. The WSAP is effective on the date specified in the
published declaration; however, rate increase may go into effect later, depending on a
customer’s bill cycle to avoid applying rate increase to water consumed prior to the water
shortage’s effective date. The following rates would be increased in accordance with the
Action Summary Table:
• City Code Section 26-127. Schedule B, metered rates:
o Commercial and residential (single-family, duplex, and multifamily)
volumetric rates (excludes base and unit rates and participants of the
Income Qualified Assistance Program receiving a discount for base and
Tier 1 volumetric charges).
• City Code Section 26-129. (b)(4) Schedule D, miscellaneous fees and charges:
o Fire hydrant and water filling station volumetric rates.
EXHIBIT B
Fort Collins Utilities 11 2020 Water Shortage Action Plan (WSAP)
ACTION SUMMARY TABLE
Fort Collins Utilities Water Shortage Action Plan
Action Level
Water Shortage
Watch -
Voluntary
I - Low II - Medium III - High IV - Alternative
% Projected Water Shortage Potential shortage 1-15% 16-25% 26-35%
Unique and
extreme water
shortages not
adequately or
appropriately
addressed by
Water Shortage
Watch or Levels I-
III
Indoor Use Reductions Voluntary
Indoor rationing to
address extreme
water shortages (>
35%) and select
restriction(s) listed
in Action Levels I-III
to address other
unique scenarios
Outdoor Use Reductions
Landscape Water Use
Lawn Watering
Target: 0.62
gallons/sq. ft. or 1"
per week
Target: 0.62
gallons/sq. ft. or
1" per week
Target: 0.47
gallons/sq. ft. or
0.75" per week
Requirement: 0
gallons/sq. ft. per
week
Non-Watering
Hours
No watering
between 10 a.m.
and 6 p.m.
No watering
between 10 a.m.
and 6 p.m.
No watering
between 10 a.m.
and 6 p.m.
N/A
Number of
Watering Days per
Week (even and
odd refers to the
last digit of a street
address)
Fort Collins Utilities 12 2020 Water Shortage Action Plan (WSAP)
Sprinkler System
Maintenance
Minimize test run
times per zone
Minimize test run
times per zone
Minimize test run
times per zone
Not allowed
Trees
Limit watering to two
days per week and
not between 10 a.m.
and 6 p.m., and by
hand, drip system or
deep root fork or
needle at any time
May be watered
by sprinkler on
Residential (even)
- Th & Sun
Residential (odd)
- Wed & Sat
Multifamily &
Commercial - Tue
& Fri. any day,
other than
between 10 a.m.
and 6 p.m., and
by hand, drip
system or deep
root fork or needle
at anytime
May be watered by
sprinkler on
Residential (even) -
Sun
Residential (odd) -
Sat
Multifamily &
Commercial – Fri.,
other than between
10 a.m. and 6 p.m.
May be watered
only by hand, drip
system or deep
root fork or needle
at anytime
May be watered
only by hand, drip
system or deep
root fork or needle
at any time
Indoor rationing to
address extreme
water shortages (>
35%) and select
restriction(s) listed
in Action Levels I-III
Fort Collins Utilities 13 2020 Water Shortage Action Plan (WSAP)
Other Landscapes
Limit watering to two
days per week and
not between 10 a.m.
and 6 p.m., and by
hand or by drip
system at any time
May be watered
by sprinkler on
Residential (even)
- Th & Sun
Residential (odd)
- Wed & Sat
multifamily &
Commercial - Tue
& Fri. any day,
other than
between 10 a.m.
and 6 p.m., and
by hand or by drip
system at anytime
May be watered by
sprinkler on
Residential (even) -
Sun
Residential (odd) -
Sat
multifamily &
Commercial – Fri.,
other than between
10 a.m. and 6 p.m.
May be watered
only by hand, or
drip system at
anytime
Not allowed
Non- Landscape Water Use
Residential Vehicle
Washing
Must use shutoff
nozzle
Must use shutoff
nozzle
Not allowed from
May-August. Must
use shutoff nozzle
Not allowed
City of Fort Collins
Fleet Vehicle
Washing
As needed
Once per week or
as approved by
the City Manager
for health or
safety reasons
Not allowed unless
approved by the
City Manager for
Fort Collins Utilities 14 2020 Water Shortage Action Plan (WSAP)
methods must be
deployed first
Dust Control
Measures for Dust
Generating
Activities
Whenever possible
use alternative (non-
water) dust control
measures, as
defined by the City’s
Dust Prevention and
Control Manual
Unrestricted -
consider water
shortage watch
measure
Unrestricted -
consider water
shortage watch
measure
Not allowed, except
if no alternative
(non-water) dust
control measures
exist, as defined by
the City’s Dust
Prevention and
Control Manual
Indoor rationing to
address extreme
water shortages (>
35%) and select
restriction(s) listed
in Action Levels I-III
to address other
unique scenarios
Street Sweeping
No more than
normal operating
schedule and
essential street
sweeping.
Whenever possible,
deploy dry methods
first
Unrestricted -
consider water
shortage watch
measure
Local Street
sweeping shall be
limited to essential
street sweeping
only. Whenever
possible, dry
methods must be
deployed first
Arterial and
Fort Collins Utilities 15 2020 Water Shortage Action Plan (WSAP)
Water Features
Turn off water
feature
Unrestricted -
consider water
shortage watch
measure
Not allowed Not allowed
Splash Parks
Operate system to
maximize water
reuse while
maintaining water
quality
Unrestricted -
consider water
shortage watch
measure
Unrestricted -
consider water
shortage watch
measure
Not allowed
Community
Outdoor
Swimming Pools
Use pool cover and
backwash system if
exists
Unrestricted -
consider water
shortage watch
measure
Unrestricted -
consider water
shortage watch
measure
Unrestricted, if filled
before date
restrictions were
implemented. No
filling of empty
pools
Individual Outdoor
Swimming Pools
and Recreational
Water Toys
Limit use by setting
a spigot timer on the
hose
Unrestricted -
consider water
shortage watch
measure
Toys not allowed.
Pools are
unrestricted, if filled
before date
restrictions were
Fort Collins Utilities 16 2020 Water Shortage Action Plan (WSAP)
Exceptions by Permit
New Lawn
Installation (sod
and seed)
Not applicable
Water any time of
day and any day
of the week for a
period of time, as
defined by the
approved permit.
Multifamily and
Commercial can
request a
temporary
certificate of
occupancy
September-April
installation, water
any time of day and
any day of the
week for a period of
time, as defined by
approved permit.
Multifamily and
Commercial can
request a
temporary
certificate of
occupancy
No exceptions.
Multifamily and
Commercial -
temporary
certificate of
occupancy will be
allowed
Medical Hardship
Water on two
selected days per
week. No
watering on
Monday and
between the
hours of 10 a.m.
and 6 p.m.
Water on one
selected day per
week. No watering
on Monday thru
Thursday and
between the hours
of 10 a.m. and 6
p.m.
No exceptions
Religious
Objection
Water on two
selected days. No
Fort Collins Utilities 17 2020 Water Shortage Action Plan (WSAP)
Inactive Areas with
Turf Areas of Four
Acres or More and
City Parks
Max of 1.00" or
0.62 gallons per
sq. ft per week.
Water 3
days/week. No
watering between
the hours of 10
a.m. and 6 p.m.
Max of 0.75" or
0.47 gallons per sq.
ft. per week. Water
3 days/week. No
watering between
the hours of 10
a.m. and 6 p.m.
No exceptions
Active Area City
and Community
Athletic/Playing
Fields
Max of 1.25" or
0.78 gallons per
sq. ft. per week.
May water any
day, according to
permit; no
watering between
the hours of 10
a.m. and 6 p.m.
Max of 1.0" or 0.47
gallons per sq. ft.
per week. May
water any day,
according to permit;
no watering
between the hours
of 10 a.m. and 6
p.m.
No exceptions
Well or Raw Water
Registration and
sign provided by
Utilities required
Registration and
sign provided by
Utilities required
Registration and
sign provided by
Utilities required
Enforcement
Residential Fines
per Violation
Not applicable
$50-1,000 $100-1,000 $100-1,000 $50-1,000
Non-Residential
Fort Collins Utilities 18 2020 Water Shortage Action Plan (WSAP)
Additional requirements during Action Levels I-IV:
• Watering within 48 hours of a rain event is prohibited.
• Hand watering requires use of a shut off nozzle.
• Drip or deep fork/needle irrigation requires use of a spigot or other automatic irrigation system timer.
• Permits must be displayed so they are visible from the street or sidewalk.
Recommendation: Utilize cycle soak watering methods by breaking up watering in each irrigation zone into 2 cycles, with at least 60 min. in between
to allow water to soak into the ground.
EXHIBIT B
Fort Collins Utilities 19 2020 Water Shortage Action Plan (WSAP)
1.3 Declaring a Water Shortage
Prior to declaring a water shortage, the following steps should occur:
1. Water Shortage Indicators (Section 1.4) and other necessary information is
analyzed by Utilities and presented to the Action Committee (Section 1.6).
2. The Action Committee develops a recommendation with supporting data,
description of the evaluation, and the proposed response.
a. If Action Level IV is recommended, additional information should be
provided to the City Manager that includes a description of which
restriction(s) are recommended from the Action Summary Table (Section
1.2) and why; or in the case of an extreme water shortage, which types of
indoor water uses will be rationed and to what degree or extent.
3. The recommendation is presented to the City Manager.
4. The City Manager considers the Action Committee’s recommendation to
determine whether to declare a water shortage and, if so, which action level to
select.
a. If Action Level IV is selected, the City Manager must include a description
in the declaration of which restriction(s) are selected from the Action
Summary Table; or in the case of an extreme water shortage, which types
of indoor water uses will be rationed and to what degree or extent.
When possible, City Council will be informed in advance of the water shortage
declaration. A water shortage declaration may need to be made quickly, in order to
minimize the severity of the shortage. In these instances, City Council will be notified as
quickly as possible following the water shortage declaration.
After the declaration of a water shortage, the City Manager shall issue a declaration and
order pursuant to City Code 26-167(a), in conjunction with the City Attorney’s Office and
City Clerk.
Moving Between Levels and Returning to Normal Conditions
The Water Shortage Indicators will continue to be monitored throughout the given water
shortage. It may be necessary to increase the action level to either achieve greater
demand reduction or reduce the action level, but not yet return to normal conditions.
Moving between action levels or returning to normal conditions requires a declaration by
the City Manager, using the process defined above, pursuant to City Code 26-167(a).
1.4 Water Shortage Indicators
Several indicators are used to monitor water supplies and demands, evaluate the
severity of a potential water shortage, including length and projected duration, and
ultimately guide the appropriate response. The indicator list below is not comprehensive
nor representative of all possible scenarios; additional relevant information will be
utilized if available.
• CBT water supply availability. Utilities owns units in the Colorado-Big Thompson
(CBT) project, which are subject to a variable annual quota that determines how
much water each unit will yield. Northern Water operates the CBT project. Often, a
low quota is first declared in November, with an updated, additional quota provided in
early April. There are rare times when additional quota is provided in mid-summer,
EXHIBIT B
Fort Collins Utilities 20 2020 Water Shortage Action Plan (WSAP)
but typically the total annual quota ranges between 50 and 100% (e.g., 100% quota
= 1 acre-foot per unit).
The CBT project provides supplemental water supplies for the region. The quota is
set high when other regional water supplies are expected to be below normal and the
quota is set low when regional water supplies are plentiful. However, when storage in
the CBT system is low, the quota may become what is known as “supply-limited”. A
supply-limited quota is a strong indicator to anticipate a reduced CBT supply in the
current or following season, especially if the snowpack is below average. A predictor
of a supply-limited quota is the volume of unallocated project reserves in the CBT
project.
• Windy Gap water availability. Through an agreement between Utilities and multiple
parties called the “Reuse Plan,” Utilities usually receives Windy Gap water each year
through the CBT system. The presence or lack of Windy Gap water supplies in the
CBT system, or the ability to create Windy Gap in-lieu of water from CBT supplies,
can make a significant difference in the volume of supplies available via Horsetooth
Reservoir, therefore staff monitors these levels closely.
• Poudre River water availability. Poudre River water supplies are estimated based on
either:
o A projected date when each of Utilities’ Poudre River water rights will fall
out of priority.
o The volume that is expected to be diverted by Utilities given water quality
and infrastructure constraints.
Estimates are informed by regional streamflow projections that consider snowpack,
weather forecasts and other factors.
• Joe Wright Reservoir storage levels and Michigan Ditch flows. Another source of
Utilities’ supply is the Joe Wright Reservoir-Michigan Ditch system. The amount of
water diverted by the Michigan Ditch is dependent on the water supplies in the
Michigan River, which is not a tributary of the Poudre River. A reduction of Michigan
Ditch diversions and/or Joe Wright Reservoir not filling would be strong indicators or
a need to monitor the supply and demand balance closely and to anticipate reduced
supplies in the given or following year.
• Snowpack surveys and streamflow estimates for the Poudre River and Colorado
River basins. Both the Poudre River and the CBT system rely on snowpack to fill
reservoirs and rivers, which ultimately deliver water to our community when the snow
melts. The spring runoff (timing and volume of melting snowpack), in conjunction with
available storage, influences how much water will be available to treat each year.
Data on snowpack and streamflow comes from:
o National Resources Conservation Services Snotel program readings for Joe
Wright and Deadman Hill sites provide information about winter snowpack in
the Poudre River basin.1
1
This information can be accessed here: wcc.sc.egov.usda.gov/nwcc/site?sitenum=551;
wcc.sc.egov.usda.gov/nwcc/site?sitenum=438
EXHIBIT B
Fort Collins Utilities 21 2020 Water Shortage Action Plan (WSAP)
o The State of Colorado Division of Water Resources provides monthly snow
course data in the Poudre River basin, which includes information about
snow conditions at a variety of elevations. 2
o Northern Water provides snowpack and streamflow projections for the
Colorado River and Poudre River basins. 3
• Weather Forecasts and Drought Monitors. Short- and long-term national and regional
weather predictors and drought condition monitoring information are used to
anticipate if we may expect lower than average supplies and/or higher than average
demands. Several governmental and educational online resources are monitored to
assess these conditions, including drought monitors, seasonal drought outlooks and
monthly and seasonal climate outlooks.
• Water quality issues. Water quality can impact the ability to treat and therefore make
use of Utilities’ water supplies. These include short-term issues like vehicle crashes
in the Poudre River and longer-term issues like algal blooms in Horsetooth. Utilities
monitors both water sources for any potential impacts.
• Natural disasters. Wildfires or floods in the Poudre River basins, other source
watersheds (e.g., Colorado or Michigan River basins), or within the service area can
impact water quantity, water quality and/or water infrastructure, potentially for
multiple years.
• Infrastructure failures. The presence of an infrastructure failure event can suddenly
cause a supply shortage if it impacts Utilities’ ability to divert raw water supplies to
the water treatment plant or impacts the distribution system and the ability to deliver
water to customers.
• Infrastructure maintenance. Planned maintenance that affects various infrastructure
that stores and delivers raw or treated water, like maintenance of the Horsetooth
outlet or the Poudre River pipelines, can cause temporary shortages of supplies.
• Administrative and governmental changes. There may be changes in water rights
administration, legislation passed by the State of Colorado, policies from Northern
Water, emergency declarations by the governor, federal Colorado River issues, or
other changes that could adversely impact Utilities’ supplies in both the Poudre River
and/or Horsetooth.
• Regional impacts and messaging. Although Utilities may have adequate water
supplies that do not warrant mandatory restrictions, other adjacent and local water
providers (e.g., other treated water providers in the Growth Management Area) might
require them. Consideration should be given to potentially aligning restriction levels
and messaging with these water providers.
2
This information is developed using hand-measured snow course reading to provide a local condition. It
can be obtained from the State of Colorado Division of Water Resources.
3
This information can be accessed here: northernwater.org/WaterProjects/WaterData.aspx
EXHIBIT B
Fort Collins Utilities 22 2020 Water Shortage Action Plan (WSAP)
Water Supply Operations Model
WRD staff maintain a water supply operations model that uses many of the above data
sources to estimate water supplies and demands. The model provides estimates for a
spectrum of scenarios from worst case (high demand and low supply) to best case (low
demand and high supply). The following figure summarizes some of the information from
the operations model.
• Water supply estimates are based on projected yields available to Utilities from the
Poudre River (including Michigan Ditch/Joe Wright Reservoir system), CBT and
Windy Gap water supplies, as described above.
• Utilities’ service area estimates average water demand (based on a 10-year rolling
average of past daily demands), which are adjusted as needed for expected
population growth. Also based on previous years water use data, potential high (dry-
year) and low (wet-year) demands are estimated.
• The model also reflects obligations to other entities (e.g., East Larimer County Water
District, Fort Collins-Loveland Water District, West Fort Collins Water District, etc.).
• Short- and long-term weather and climate factors influence the estimates of both
supplies and demands.
EXHIBIT B
Fort Collins Utilities 23 2020 Water Shortage Action Plan (WSAP)
1.5 Other Response Strategies
The following are potential actions that can be considered, if available and cost-effective,
to improve existing supplies for the current water year and improve storage reserves for
the next water year. The actions implemented will depend upon the nature and severity
of the supply shortage and should be considered complementary to a demand reduction
response. The cost-effectiveness of each short-term supply strategy should be
evaluated prior to implementing, as acquiring additional supplies can have significant
costs.
• Seek and implement potential rentals, trades or other ways to increase supplies from
others (particularly CBT supplies).
• Cease all non-binding rentals on types of water that can be used by Utilities.
• Manage Utilities’ Poudre River water rights portfolio so that maximum benefit can be
attained from each water right.
• Communicate with Utilities’ Water Treatment Facility staff regarding the availability of
the Horsetooth and Poudre River sources so that operational adjustments can be
made to treat less than optimal blends.
• Request that Utilities’ Water Treatment Facility staff use its UV treatment system to
increase supply efficiencies.
• Work with other City departments (e.g., Parks) to maximize available treated water
supplies.
• Consider any potential changes to water delivery agreements that could minimize
Utilities’ obligations under drought conditions.
1.6 Responding to a Water Shortage
Implementation
The following table outlines roles and responsibilities during a shortage. Additional roles
and responsibilities will be specified by the Water Shortage Action Committee for each
water shortage, in order to accurately address the given situation and appropriately
address implementation needs.
Department Roles and Responsibilities
Utilities – Water Conservation Administers the WSAP, including but not
limited to:
• Updating staff and the public.
• Being source of information on
restrictions, action levels, enforcement
and communication.
• Organizing the Action Committee.
• Evaluating demand trends in
coordination with Water Resources.
Utilities – Water Resources • Evaluates and monitors water supply
and demand management efforts and
the source of all information regarding
the status of the shortage.
• Coordinates closely with Water
Conservation.
Neighborhood Services – Code
Compliance
Assists with enforcement during
mandatory water use restrictions.
EXHIBIT B
Fort Collins Utilities 24 2020 Water Shortage Action Plan (WSAP)
Utilities – Finance Monitors and reports on changes in
revenue.
Utilities – Communications and
Marketing
Develops, implements, and responds to
water shortage communications,
materials and messaging following
guidance provided in Appendix A.
Utilities – Community Engagement • Assists with development of
engagement planning and
implementation.
Action Committee • Meets annually, before and during a
declared water shortage.
• Evaluates water shortage indicators
and other pertinent information
necessary for determining a water
shortage.
• Develops a water shortage
declaration recommendation to the
City Manager, including the proposed
action level.
Monitoring
It is important to measure the success of the WSAP in achieving the supply and demand
goals for the given water shortage. WRD has the primary responsibility for monitoring
the ongoing status of the water shortage and comparing demand scenarios described
below. Water Conservation has the primary responsibility for monitory public responses
to restrictions, which can be implemented during public engagement activities (see
Appendix A for more details). This monitoring may use both scientific analysis and
anecdotal information and may include:
• Comparison to actual water use with target, average and expected use (without
supply shortage awareness).
• Monitoring public response to water shortage restrictions (voluntary or mandatory)
through informal feedback, focus groups, surveys or other appropriate methods.
Water Shortage Committees
Annually and when preparing for and during a water shortage, the Action Committee
shall convene. Prior to and during a water shortage the Stakeholder Committee shall
also meet, as needed. Representation on both committees shall include the following
service areas and departments:
ACTION COMMITTEE
Critical to annual evaluations, daily activities, and action plan management and leadership. The
Action Committee should meet as needed, and at a minimum, annually (preferably directly after
the April CBT quota is issued by Northern Water) to evaluate the raw water model and other
indicators and determine the supply outlook for the remainder of the year. Prior to and during a
water shortage, the primary group may meet more frequently. Depending on the water shortage
scenario, representation on the Action Committee may vary from year to year and differ from the
list below:
Utilities Executive Director
EXHIBIT B
Fort Collins Utilities 25 2020 Water Shortage Action Plan (WSAP)
Deputy Director – Customer Connections
Deputy Director – Water Production
Water Treatment
Water Resources
Water Conservation
Customer Care and Technology
Finance
Community Engagement
Communications and Marketing
Customer Accounts
Emergency Preparedness and Security
STAKEHOLDER COMMITTEE
Key to ensuring Citywide cohesiveness and consistency in messaging, implementation and
adherence to water restrictions. Representation from this group may change and meeting
frequency will reflect need, depending on the water shortage scenario.
Communication and Public Involvement Office
Parks
Forestry
Golf
Operation Services
Natural Areas
Recreation
Planning, Development, Transportation
Development Review
Neighborhood Services/Code Compliance
Environmental Services
Transfort
Adjacent water districts
Utilities
Environmental Regulatory Affairs
Distribution System
Water Reclamation
Water Quality Services
Chapter 2 Permits
Permits are available to allow for exceptions to assigned watering days and frequencies
only, as described in this chapter.
2.1 Types of Permits
Permits may be issued for individuals or businesses unable to comply with watering
restrictions for the following conditions:
• New seed and sod
• Medical/physical hardship
• Religious objection
• Large (four acres or greater) and City parks inactive areas
• City and Community active areas
• Raw or well water use
EXHIBIT B
Fort Collins Utilities 26 2020 Water Shortage Action Plan (WSAP)
New Seed or Sod Permit
This permit is to allow additional watering for new seed and sod installations. A complete
permit application is required, along with a receipt for seed or sod, seed or sod species
type, and proof of soil amendment and amount in cubic yards. Regionally adaptive
species may allow for longer or different watering exceptions compared to Kentucky
Blue Grass. When appropriate, a permit will be issued as outlined below:
Action Level I: A permit will allow for watering any time of day and any day of the
week for a period, defined by the approved permit, based on the species’
establishment needs.
Action Level II: No seed or sod planting May to August. From September to April, a
permit will allow for watering any time of day and any day of the week for a period,
defined by the approved permit, based on the species’ establishment needs.
Action Level III: No permits will be issued.
Multifamily and commercial developments can request a temporary certificate of
occupancy to allow occupancy while delaying the installation of a landscape. The entire
landscape cannot be watered unrestricted with this permit, only the areas with new seed
or sod. Other areas must be watered according to the water restrictions specified by the
action level in effect. Permit holders will be encouraged to water during the cooler times
of day after the first week.
Medical/Physical Hardship
This permit is to establish an alternate watering schedule for customers with short-term
or long-term medical or physical hardship to one or more days to which they are
otherwise assigned. A complete permit application is required. Utilities reserves the right
to verify the medical or physical hardship for which the permit is being issued.
Action Level I: Watering on two specified days per week. No watering Monday or
between 10 a.m. and 6 p.m.
Action Level II: Watering on one specified day per week. No watering Monday
through Thursday and between the hours of 10 a.m. and 6 p.m.
Action Level III: No permits will be issued.
Religious Objection Permit
This permit is to establish an alternate watering schedule for customers with religious
objections to one or more days to which they are otherwise assigned. A complete permit
application is required. Utilities reserves the right to verify the religious objection for
which the permit is being issued.
Action Level I: Watering on two specified days per week. No watering Monday or
between 10 a.m. and 6 p.m.
Action Level II: Watering on one specified day per week. No watering Monday
through Thursday or between 10 a.m. and 6 p.m.
Action Level III: No permits will be issued.
EXHIBIT B
Fort Collins Utilities 27 2020 Water Shortage Action Plan (WSAP)
Large (Four Acres or Greater) and City Parks Inactive Areas Permit
This permit is to establish a custom watering schedule for privately-owned areas with
four acres or more or City parks of any size, that use treated water, excluding areas with
active athletic/playing fields. Documentation that the existing sprinkler system cannot
water the area within the designated watering days and watering limits are necessary to
be eligible for this permit. A complete permit application is required. Utilities reserves the
right to inspect the controller(s) and schedules associated with the permit to verify that
the setting matches the submitted application. Averaging the amount of water applied
throughout the area, is allowed.4
Action Level I: Average maximum of 1.00 inches or 0.62 gallons per square-foot per
week. Watering may occur on three specified days per week. No watering between
the hours of 10 a.m. and 6 p.m.
Action Level II: Average maximum of 0.75 inches or 0.47 gallons per square-foot per
week. Watering may occur on three specified days per week. No watering between
the hours of 10 a.m. and 6 p.m.
Action Level III: No permits will be issued.
City and Community Active Areas Permit
This permit is to establish a custom watering schedule for City parks and areas owned
by other entities that consist of playing and athletic fields that use treated water.
Documentation that the existing sprinkler system cannot water the area within the
designated watering days and watering limits are necessary to be eligible for this permit.
These areas are subject to less restriction in order to protect more actively used
landscapes and maintain safety for those using the areas. A complete permit application
is required. Utilities reserves the right to inspect the controller(s) and schedules
associated with the permit to verify that the setting matches the submitted application.
Averaging the water use application throughout the area is allowed (see footnote 4, for
more details).
Action Level I: Average maximum of 1.25 inches or 0.78 gallons per square-foot per
week. May water any day, as defined within a permit; no watering between the hours
of 10 a.m. and 6 p.m.
Action Level II: Average maximum of 1.0 inches or 0.47 gallons per square-foot per
week. May water any day, as defined within a permit; no watering between the hours
of 10 a.m. and 6 p.m.
Action Level III: No permits will be issued.
Well or Raw Water Sources
Customers who use a well or raw water source for lawn watering or other irrigation are
not restricted because this water is not provided by Utilities and is not subject to the the
WSAP. Customers using a well or raw water for irrigation are required to register their
address so that if a complaint is received, it can be disregarded. Those customers must
post a sign that is visible from the street. Free signs will be supplied by Utilities.
4 Averaging occurs by determining the total amount of water applied to the property each week and dividing
it by the area of property subject to the permit. The total water applied per square foot must be equal or less
than the maximum application specified for the applicable action level, per the permit. This allows some
areas of the property subject to the permit to receive more water and other areas less water than the
maximum application.
EXHIBIT B
Fort Collins Utilities 28 2020 Water Shortage Action Plan (WSAP)
2.2 Permit Application and Process
Customers may obtain a permit application or renewal form by downloading the
application form from Utilities’ website or by requesting one by mail or email. Complete
applications must be submitted to Utilities.
Utilities staff must use reasonable discretion when reviewing permit applications for
approval or applying terms and conditions to approve permits. Utilities staff must
consider the impacts of the permitted activity on Utilities’ water supply or water system
operations. Utilities staff may conduct investigations in the review of the permit
application.
When a permit application meets the eligibility requirements, a permit will be granted and
issued by Utilities’ Executive Director. Decisions on permit applications will be
determined within five business days of receipt, unless the permit is incomplete or
requires additional investigation. A determination of a permit will be provided in writing to
the applicant with an explanation of the basis of approval or denial. Permits may contain
terms and conditions, as determined by Utilities staff, to allow the minimum watering
necessary to carry out the intent of the permit.
Properties with approved permits remain subject to enforcement of restrictions outside of
the terms of the permit.
At Utilities’ discretion, some permits may be renewed during subsequent water
shortages. A request to renew a previously approved permit must be made to and
approved by Utilities on a renewal form provided by Utilities. The applicant must confirm
that the previously approved conditions and permit terms will be adhered to. Renewals
are subject to staff review and approval and may include additional requirements or
amendments to the previously approved permit so that the renewed permit conforms to
this WSAP and the water shortage declaration at that time.
Not all permits can be renewed. New sod and seed permits shall not be available for
renewal. Other permits shall not be renewed if there have been changes to properties’
landscape, irrigation, or other circumstances. Other permits shall not be renewed if they
are inconsistent with the current WSAP. Where a permit cannot be renewed, customers
can still submit applications for new permits under the current WSAP.
Permit Approval Process – New and Renewal Applications
1. All permit applications are submitted to Utilities for an initial review to determine if
the application is complete. If additional information is required, staff will contact
the applicant to obtain missing information.
2. Staff reviews application and presents a recommendation to Utilities’ Executive
Director or his/her designee(s).
3. If a permit is granted by Utilities’ Executive Director or his/her designee(s), a
permit number is assigned. If a permit is denied by Utilities’ Executive Director or
his/her designee(s), then an explanation of the basis will be provided to the
applicant.
4. Staff notifies customer and provides applicable water use information and
signage.
EXHIBIT B
Fort Collins Utilities 29 2020 Water Shortage Action Plan (WSAP)
5. If the level of restrictions is changed, communication will be made to all permit
holders advising of the change and required changes to water use.
Signage
Upon permit approval, Utilities will provide a sign to be posted in a location that is visible
from the street for the duration of the exemption. Signs should be returned to Utilities for
reuse following the term of the permit or the conclusion of the water shortage.
Permits and Changing Action Levels
Permit holders will be notified if the Action Level changes during the term of their permit.
Once notified, it is the responsibility of the customer to revise their watering schedule to
meet the new requirements. New Sod and Seed permits are the exception; the terms of
the permit are good until the expiration date listed on the permit.
Appeals
Final permit determinations may be appealed pursuant to City Code Section 26-53.
Chapter 3 Enforcement
The enforcement and permitting functions for Utilities’ water restrictions are designed to
ensure compliance with the WSAP, as well as City Code Section 26-166 (Prohibition of
waste). Enforcement of restrictions, together with ongoing public education and
outreach, are needed to achieve the goal of decreasing water demand, thus minimizing
the need for greater water restriction action levels. It is vital to the success of the
enforcement program that customers perceive fair enforcement of restrictions, while
receiving the necessary information to successfully comply, along with permits for
specific situations as noted in Chapter 2.
3.1 Need for Additional Resources
The implementation and enforcement of water use restrictions will likely require
additional financial and personnel resources.
3.2 Fines for Violations
Compliance with the WSAP shall be subject to City Code Section 26-168 (Obligation to
comply; penalties). Violations of the WSAP, including noncompliance with restrictions
imposed during a declared water shortage or the terms of a permit issued hereunder,
shall therefore be a civil infraction and shall be subject to the penalty provisions of
Subsection 1-15(f) of City Code, except that, notwithstanding the provisions of
Subsection 1-15(f), fines for violations of the WSAP shall be follows:
Water
Shortage
Watch -
Voluntary
I - Low II - Medium III - High
IV -
Alternative
Residential
Fines per
Violation
Not
applicable
$50-1,000 $100-1,000 $100-1,000 $50-1,000
EXHIBIT B
Fort Collins Utilities 30 2020 Water Shortage Action Plan (WSAP)
Each day during which a violation of any term of the WSAP or permit issued hereunder
occurs or continues shall constitute a separate offense.
3.3 Enforcement Guidelines
Business and Residential Violations
The restrictions shall apply to Utilities residential and business water customers, whether
within or outside of the City of Fort Collins. Premises within City of Fort Collins municipal
limits that are served water by other water providers must comply with their water
provider’s restrictions, if applicable. In the case of single-family and duplex dwellings, the
Notice of Complaint, Warning, or Citation should be issued to the Utilities account
holder. If the customer responsible for the violation is renting a residential property, it is
possible that the property owner may also be responsible for allowing the tenant or
others to use water in a manner in violation of the restrictions.
In the case of businesses and multi-family residential violations, the summons and
complaint should be issued to the person Utilities account holder – either the property
owner or the tenant, if renting. If the identity of that person is unknown, and/or to the
owner of the business or the registered agent of the business is unknown, the
information can be obtained from the Colorado Secretary of State website. The City
Attorney’s Office can assist as necessary.
Methods of Enforcement
Utilities’ water conservation programs are based on an educational approach with
proactive public outreach. Depending on the severity of the shortage and other factors,
this approach may be continued with mandatory water restrictions, to engage and
maintain the willing cooperation and support of customers.
Utilities’ goal of enforcement is to encourage all customers to help with conserving water
during a shortage. The WSAP allows for citations to be issued following a warning.
During mandatory levels, enforcement may be implemented using various methods,
including the following:
• Complaint-based enforcement
• Active patrolling and violation identification by Utilities and Code Compliance
• Remote monitoring by Utilities, using advanced metering infrastructure
Educational Resources
Existing Water Conservation Division programs and services can be used to assist
customer with compliance challenges:
• Sprinkler Audit Program – irrigation controller changes included
• WaterSmart Customer Portal – monitor water use
• Rebates – improve indoor and outdoor water use efficiency
Non-
Residential
Fines per
Violation
$250-1,000 $500-1,000 $500-1,000 $250-1,000
EXHIBIT B
Fort Collins Utilities 31 2020 Water Shortage Action Plan (WSAP)
• Xeriscape Incentive Program – convert high-water use landscapes to regionally
adapted water-wise landscapes
• Landscape Water Budget Program – compares recommended water use to
current water use to identify inefficiencies
Reporting Complaints
Customers may report water shortage violations and related complaints by contacting
Utilities through a number of ways:
• Saving Water Hotline4: (970) 416-2881, answered live during working hours or
voicemail
• Email: utilities@fcgov.com
• Access Fort Collins – water restrictions category: fcgov.com/accessfortcollins
Information needed for enforcement staff to investigate the report:
• Complainant’s name and contact information (may be anonymous)
• Address or specific location where the violation occurred
• Date and time the violation was observed
• Details about the violation (wrong day, wrong time, wasting water, etc.)
3.4 Turning Off Water
Reports are occasionally received where sprinklers or other water uses have been
running for hours or days and all means of reaching the customer have failed. In those
cases, Utilities staff can enter the property to shut off the sprinklers. See City Code
Section 26-22 (Right of Entry) and Section 26-28(f) (Abatement of Imminent Hazards).
Chapter 4 WSAP Updates
4.1 WSAP Review
Utilities’ customers and stakeholders across the City organization and community will be
included in any review and update process. Water shortages and related demand
reduction strategies impact the community in a variety of ways, and any review will
benefit from a broad and diverse public and stakeholder engagement process, including
under-represented populations. For technical and professional recommendations,
Colorado Water Conservation Board (CWCB) should be included in a WSAP review
process. CWCB can provide insight from the State and regional level, as well as provide
funding for water shortage planning and implementation.
4.2 Public Review Process
During any review and update process, Utilities staff will engage stakeholders and the
public to share what a water shortage is, the value of a prepared action plan, the current
WSAP, and solicit input on the WSAP and potential updates. Methods of engagement
may include print and online materials and resources; in-person workshops, focus
4
This hotline is also used to report wasted water year-round regardless of a water shortage declaration, in
accordance with City Code Section 26-166.
EXHIBIT B
Fort Collins Utilities 32 2020 Water Shortage Action Plan (WSAP)
groups, presentations; and, digital tools, such as social media and electronic surveys.
The method used will depend on the extent of the review and updates needed.
Stakeholders to engage include, but are not limited to:
• Affordable housing providers
• Business Associations
o Chamber of Commerce
o North Fort Collins Business Association
o Midtown Business Association
o Downtown Business Association
o Downtown Development Authority
• Carwashes
• Certified Landscape Professionals and others in the landscape industry
• Faith-based and other non-profit organizations
• Key Accounts
• Vehicle Dealerships
Public engagement methods include, but are not limited to:
• Events like:
o Bike to Work Day
o Open Streets
o Water Conservation or other Utilities events
• OurCity – interactive website
• Utilities Bill insert
• Water Reports
City Staff to engage include, but are not limited to:
• Code Compliance
• Natural Areas
• Operation Services
• Parks:
o Forestry
o Golf
• Planning and Development
• Recreation
• Streets
• Sustainability Services
• Transfort
• Utilities:
o Customer Accounts
o Customer Care and Technology
o Distribution
o Finance
o Water Resources
o Wastewater Treatment
o Water Treatment
o Water Quality
EXHIBIT B
Fort Collins Utilities 33 2020 Water Shortage Action Plan (WSAP)
4.3 Updates
Regular and frequent review of the WSAP and water shortage action measures is critical
to ensure Utilities’ staff and customers are prepared for a water shortage. The WSAP
should be reviewed at least every five years, or sooner as new information becomes
available. Updates may be necessary during or following a water shortage event,
updates to either the Water Supply and Demand Management Policy or the Water
Efficiency Plan, or changes to City Code. The next update should be considered in
2023-2024 for potential adoption in 2025.
Updates for 2025 or Sooner
Updates for future versions of the WSAP were identified during the review and
development of the current WSAP but could not be explored or incorporated due to
resource or other constraints. The identified opportunities include:
While there are challenges to a regional water shortage approach, mainly being that
water providers in the area do not have the same water supply portfolios, infrastructure,
demands, or levels of service and; therefore, not all providers will experience shortages
at the same time or to the same extent. Staff identified that there is potential grant
funding available to develop a more regional type of approach but would require
additional resources. Benefits to regional collaboration could include the following:
• Enhance existing and create new mutual aid agreements.
• Improve resiliency on a regional level regardless of water provider.
• Minimize customer confusion and experience of disjointed approaches.
Water Budgets is a method of assigning a target water use level based on
characteristics of the property. The level or “budget” may be a function of occupancy,
building size, landscape size and type, type of business, etc. Water budgets can be used
for informational purposes, to inform rate structures, and/or to manage demand during a
water shortage. Significant resources and customer communication efforts would be
required to establish and administer water budgets. Beyond staffing and cost, assigning
water budgets to commercial properties would require significant technical analysis.
Benefits of a water budget approach to a water shortage could include the following:
• More equitable.
• Easier to implement during a water shortage compared to prescriptive
restrictions.
• Greater customer flexibility and choice.
Among other goals and programs, the CWCB provides technical and financial
assistance for communities and water providers wanting to develop a water shortage
plan. CWCB provided a preliminary review of the WSAP in February 2020. Some
recommendations were able to be incorporated; however, others will require additional
funding and time to integrate. Utilities should consider the challenges and benefits of
developing the following in future plan updates:
• Supply-side response strategies, like developing short-term supply agreements,
for use during a water shortage.
• Supply and demand-side water shortage mitigation strategies, like tactics to
implement prior to a shortage to minimize the likelihood of a shortage or minimize
the severity of a shortage.
EXHIBIT B
Fort Collins Utilities 34 2020 Water Shortage Action Plan (WSAP)
• Vulnerability assessments that evaluate what impacts could result from a water
shortage, like studies that assess impacts to the economy resulting from water
shortages.
EXHIBIT B
Fort Collins Utilities 35 2020 Water Shortage Action Plan (WSAP)
Appendix A Communication and
Engagement Plan
A.1 Communications and Marketing
A strong communications plan is the foundation to successful implementation of the
WSAP. Utilities recognizes the need to be prepared to communicate to customers,
stakeholders, City staff and departments, and others:
1) The water shortage situation and its associated impacts.
2) The WSAP and the water restrictions specific to the water shortage situation.
A public information campaign will need to be developed for each unique water
shortage. The campaign will be closely coordinated with Utilities’ current water efficiency
and conservation programs, as well as other key, relevant messages. The program(s)
will promote the importance of conserving water and achieving water savings in times of
plenty and in times of water shortages. During non-shortage years, a water shortage
public information campaign will instead focus on awareness of the WSAP and the
importance of preparedness.
The public information campaign will coordinate campaign efforts with nearby municipal
entities, other water providers and conservation-oriented entities to capitalize on
synergistic opportunities and convey, where appropriate, a consistent water shortage
message.
Developing key messages is important. Utilities has created an extensive list of tactics
for reaching customers with timely information about water restrictions. Messages will
include information about the nature of the water shortage, how it will affect customers
and what they can do to follow the restrictions to minimize further impacts and the need
for stronger restrictions.
Depending on capacity and other factors, Utilities may contract with a communication
consulting firm(s) to help develop effective messaging and graphic design.
Targeted outreach to internal and external customers also will be very important and is
discussed in the Engagement section, below.
The following outlines communication objectives, messages and strategies that can be
used in a variety of external communications and media during different stages of a
water shortage. The messages and examples below are not comprehensive or
necessarily exact. The current best practices for message development and delivery will
be utilized and may result in different messages that what is contained in this appendix.
A.1.1 Messaging
Objective: To inform and educate our customers and key stakeholders about the water
shortage, the water restrictions associated with the WSAP, actions to take to conserve
water, and programs available to help customers through a water shortage.
Tagline: Reduce Our Use. This tagline was chosen during the 2013 water shortage to
reflect the community commitment needed to achieve the reduction goals established.
EXHIBIT B
Fort Collins Utilities 36 2020 Water Shortage Action Plan (WSAP)
This also created a social-based, community message that we are all involved in the
solution. It could be used again, or another tagline could be created.
The following is an example of messaging that might be developed during the voluntary
level when a shortage could occur due to drought. Similar plans could be created at any
action level for any shortage situation.
Voluntary Shortage Watch Objective: Public Awareness
Water Shortage Scenario:
• Water supplies are below average.
• Conditions are dry.
• Continued dry weather could lead to mandatory watering restrictions.
Message to Public: To reduce the risk of progression to mandatory restrictions, limit
watering your lawn to two days a week before 10 a.m. and after 6 p.m. only. Watering
new seed, sod, plants, shrubs and gardens as recommended is allowed, but do not
waste water and stay alert to water shortage status changes. Minimize indoor water
waste by using water wisely: turn off faucets when not in use; shorten shower time when
possible; and ensure full loads when running dishwashers and clothes washers.
A.1.2 Key Messages
Below are key messages, both primary and secondary, to help Utilities customers
understand our water supply situation and the restrictions.
Primary Messages
Watering trees and vegetable gardens is not restricted.
Watering gardens and trees will be allowed in all levels of restrictions. Watering during
Action Level III is limited to a hose with a shut-off nozzle or by drip and microspray
irrigation.
Education is key.
Citizens can help reduce water use by educating family, neighbors and co-workers.
Education is a critical first step of enforcing restrictions.
Fines are secondary.
First violations will generally receive a written warning (though this is not required) and
information about the water restrictions.
Fort Collins has reduced its use significantly in the past decade.
Since the drought of 2002, the community has reduced overall water use by 25%. As the
population has grown, total water use by customers has decreased, which has helped
defer water shortages. Continued conservation is necessary year-round, but especially
during a water shortage.
We can all make a difference.
Everyone in our community can help conserve water at home and at work. See
fcgov.com for tips, rebates and programs.
Permits will be issued to accommodate special circumstances.
EXHIBIT B
Fort Collins Utilities 37 2020 Water Shortage Action Plan (WSAP)
Permits will allow exceptions to restrictions as set forth in the WSAP.
Utilities may go to higher action levels of restrictions.
Stay updated on the current status. Higher levels of restrictions include rate increases to
further promote conservation and recognize the reduction in revenue due to less water
use at each respective action level of the WSAP.
Restrictions apply only to treated water.
Residents and businesses that use well or raw water to irrigate grass are exempt from
the water restrictions. However, we strongly encourage them to follow the restrictions in
order to set an example for the community, avoid negative perceptions and continue to
conserve raw and well water sources. Signs must be posted.
The City of Fort Collins has reduced its water use.
The City has taken steps to reduce treated water at parks and golf courses, as well as in
its facilities. By purchasing separate water rights for irrigation, the City uses 80% raw
water on parks, golf courses and other outdoor lawn areas. Newer facilities built by the
City have exceeded requirements for water efficiency indoors, saving water year-round.
We have two main sources for drinking water: the Poudre River and Horsetooth.
The Poudre River was traditionally the source of water for Fort Collins, but as the City
grew, it purchased units in the CBT project, which are delivered out of Horsetooth. Each
source provides about half of the supply of water for treatment.
The City of Fort Collins will follow water restrictions.
The Parks department plans to adhere to current restriction levels even though 80% of
irrigation water comes from raw water. The City also plans to curtail hydrant flushing and
limit vehicle washing, per restrictions.
A.1.3 Strategies and Tactics
Below are possible strategies for reaching our communication goals. These include
outreach materials, advertising and media contacts. Spanish translation should be
considered for strategies and tactics. This list is not comprehensive.
Print Collateral
• Water restrictions brochure to explain WSAP
• Poster campaign
• Tabletop cards for “Water Served Only Upon Request” for restaurants
• Hotel/lodging cards with current City logo, restrictions, and encouragement to
reuse linens and towels
• Utility Bill Inserts
• Printed coasters with water conservation messages
• Direct mail campaigns all customers or targeted groups
Website
• Create and update a webpage on fcgov.com
• Spotlight on Utilities page and City home page
• Update Access Fort Collins
• Update conservation tips: watering, landscape/tree care, lawn dormancy
• CityNet (intranet website for City of Fort Collins employees)
EXHIBIT B
Fort Collins Utilities 38 2020 Water Shortage Action Plan (WSAP)
City Newsletter Articles
• City News
• Neighborhood Newsletter
• Keep Current
• ClimateWire and other ClimateWise communications
• Economic News
• Fort Shorts
Media Articles
• In the City articles in the Coloradoan
• News releases
• Media outreach
• Advertorials
Newspaper/Magazine Advertising
• Coloradoan
• NoCo Style Magazine
• BizWest
• Rocky Mountain Parent Magazine
• 50 and Better Magazine
• CSU Life Magazine
• PSD Newsletters
• Fort Collins Magazine
Outdoor Advertising
• Bus benches
• Bus shelters
• Bus panels
• City parks, recreation, and other public facilities
Digital Marketing
• Digital ads
• Social media (Facebook, Twitter, Instagram, Nextdoor) advertising with
organic
• FCTV CityView
• FCTV Bulletins
• Interactive Voice Response (IVR) Messages on phone system
• Sign up to receive water efficiency tips and updates and corresponding email
campaign
• Messages in bills, usage reports and portals
• Presentation materials
Displays
Design to have at events and public locations, such as City buildings, libraries and other
venues. Messages should include information about restrictions and efficient water use.
Other
EXHIBIT B
Fort Collins Utilities 39 2020 Water Shortage Action Plan (WSAP)
• Graph(s) that illustrate water supplies relative to water demands to be
updated regularly prior to and during a water shortage (consider using during
non-water shortage times as well, to develop customer awareness)
• Door panel magnets for Utilities vehicles with conservation message
• Distribute water conservation kits – hose nozzles, showerheads and aerators
• Internal communication plan for City staff
Water Restrictions Icon
Design a graphic icon for newspapers and other media for customer awareness of
restriction action levels. The icon can be updated to show different restriction levels.
Frequently Asked Questions
Frequently Asked Questions (FAQs) should been developed to help clarify and
consistently answer questions about the restrictions. General FAQs should be on the
website and a select list through Access Fort Collins.
Enforcement Materials
Prepare a packet of information that can be mailed or left as a door hanger when
complaints are received. Develop materials for enforcement communication and permits.
• Packets
o Flyers with restrictions
o Residential focus
o Commercial focus
o Violation notices
o Water restrictions: Notice of Complaint and Warning
o Wasting water: Notice of Complaint and Warning
o Brochure: watering with restrictions for lawn and tree health, landscape
care, rebates, tips, controller programming help
• Permits
o Applications with cover letters
o Approval or non-approval letters/emails
o Permit yard signs
o Raw water yard signs
o Email campaigns to communicate action level changes
A.2 Public Engagement
A well-planned public engagement program is critical to Utilities’ success in achieving
water savings goals established by each action level. Public engagement is an
extremely important step, as it asks the community to be a part of the solution during a
water shortage and can minimize enforcement efforts. A wide range of engagement
strategies should be pursued to inform internal and external stakeholders, and all
customer types.
A.2.1 Speaker’s Bureau
Utilities will consider preparing several standard presentations for the public and train
other Utilities staff as Ambassadors to give the appropriate presentation to the given
EXHIBIT B
Fort Collins Utilities 40 2020 Water Shortage Action Plan (WSAP)
audience. Updates may be provided to the speakers and presentation content, as
needed. Staff may accommodate requests for presentations and will proactively offer
presentations to known groups and organizations.
Examples of organizations and existing groups that might receive a presentation are:
Rotary Clubs, Kiwanis, Chamber of Commerce, Downtown Development Authority,
Downtown Business Association, Board of Realtors, ClimateWise partners, Certified
Landscape Professionals, Key Accounts, affordable housing providers, Colorado State
University’s clubs and student organizations, faith based organizations, non-profit
organizations that serve under-represented populations, etc.
OTHER ENGAGEMENT OPPORTUNITIES
Internal External
Develop Customer Service Representative
(CSR) script and Frequently Asked
Questions
Income-Qualified Assistance Program
customers
Give monthly presentations to update
CSRs
Latinx community organizations
Give presentations to water and light and
power crews
Poudre School District: Dr. Water Wise
and Children’s Water Festival
Presentation/training meetings – All
Staff/Large Staff/Senior Staff, etc.
Library displays
Presentation at existing team meetings Sprinkler Audit Program and controller
setting service
Provide communication materials to all Sustainable Neighborhoods
Water conservation challenge Events such as Open Streets, Earth Day,
Garden Party, ClimateWise events, High
Plains Landscape Workshops and
Watershed Tours
A.2.2 Public Engagement Goals and Tracking
Goals for public engagement should be established and progress toward completion
should be monitored and tracked. This allows activities and efforts to be reported on
during a water shortage, supports successful water savings and allows Utilities to
evaluate whether gaps exist in engagement efforts or customer segments. The following
are metrics that can be used to track progress toward the goal(s):
• Number of presentations.
• Number of people present during presentations.
• Diversity of audiences.
• Number of ambassadors trained, including tracking ambassador efforts and
consider recognizing co-workers’ contributions.
• Evaluation of effectiveness with a survey or live polling during a presentation to
possibly assess familiarity with the water shortage and understanding of
associated restrictions.
EXHIBIT B
Fort Collins Utilities 41 2020 Water Shortage Action Plan (WSAP)
A.2.3 Targeted Business and Organization Outreach
Two major educational organizations that either would be impacted during a water
shortage or can provide important partnership opportunities are Colorado State
University (CSU) and Poudre School District (PSD). CSU uses little Utilities water to
irrigate but should be considered a partner to provide consistent messages to the
general public. Information and presentations should be provided for facilities staff,
Associated Students of CSU and through CSU’s media channels (i.e. CSU Today).
Information should also be disseminated to students living off campus, including
fraternities and sororities.
Most of PSD’s athletic fields are irrigated by treated water provided by Utilities. Staff and
key account representatives should work closely with PSD through calls, meetings and
emails to facilitate understanding of the restrictions and their impacts. A meeting for all
athletic directors should be held. In partnership with PSD, various engagement
opportunities may exist to help with water shortage commutation efforts.
There are a variety of other commercial customers that may be affected by water
restrictions. The following list of customers should be considered for targeted
engagement:
• Breweries
• Retail, grocery stores, and coffee shops:
o Store visits/meetings
o In-store flyers and posters
• City’s Economic Health meeting
• Car Dealerships
o Direct mail, restrictions limit car washing
• Car Washes
o Direct mail
• Power Washing Companies
o Direct mail, restrictions limit washing for only “health and safety”
o Contact Downtown Business Association about sidewalk washing
(meeting or mailing)
• Landscapers/Nurseries/Garden Centers
• Certified Landscape Professionals bi-annual meeting or email
o Group meeting
o Direct mailing
• Homeowner Associations (HOA)
o Set up meeting/workshop
o Information with HOA audits/Landscape Water Budgets
o Direct mailing/water fountain information
o Information at Neighborhood Service’s HOA meetings
o Property management companies - send information/fountain information
• Health Clubs
o Meeting
o Signage for showers, faucets
• Hotels/Motels
o Distribute linen and towel reuse cards
• Restaurants
o Meeting/workshop
o Information with pre-rinse program
EXHIBIT B
Fort Collins Utilities 42 2020 Water Shortage Action Plan (WSAP)
o Design and distribute “Water Served Upon Request” table cards
A.2.4 Surrounding Water Districts
The neighboring water districts should be contacted prior to and during water restrictions
to discuss opportunities to align communication plans and other responses and to keep
other districts updated. The adjacent districts include:
• Fort Collins-Loveland Water District (FCLWD)
• East Larimer County Water District (ELCO)
• West Fort Collins Water District (WFCWD)
A.2.5 Agriculture Water Renters
Previous agricultural CBT water renters should be contacted if the Utilities has decided
to not conduct a raw water rental program as part of a supply-side response strategy.
A.2.6 Internal Communication
Staff will present water shortage and restrictions information to City staff and when
possible, will use established meetings. Information and updates should be provided to
City boards and commissions and City Council and Mayor. High focus should be given
to the following, who’s work may be affected by water restrictions.:
• Parks and Recreation Department
• Operation Services
• Code Compliance
• Natural Areas
• Development Review
• Communications and Public Involvement Office
• Environmental Services
• Economic Health
• Utilities:
o Water Treatment
o Water Quality
o Water Distribution
o Environmental Regulatory Affairs
o Customer Care and Technology
Utilities staff can serve as ambassadors to convey water shortage key messages to the
public. In addition, staff will partner with other City departments who can help be
ambassadors when engaging with external customers during their normal
business/work.
EXHIBIT B
Fort Collins Utilities 43 2020 Water Shortage Action Plan (WSAP)
Appendix B Relation to Other Plans
and Policies
The WSAP relates to other City plans and policies, most notably the Water Supply and
Demand Management Policy (WSDMP) and the Water Efficiency Plan (WEP).
The WSDMP sets criteria for how to plan and manage Utilities’ water supply system,
which can affect how often the WSAP may need to be used. The WEP outlines specific
measures to be implemented to reach a specified water use goal. The measures
address long-term conservation and efficiency efforts, not short-term adaptation
measures, as outlined by the WSAP.
B.1 Water Supply and Demand Management Policy
The WSAP relies on a set of water supply and demand criteria in order to evaluate real
or potential water shortages. These criteria are established by the City’s WSDMP, which
provides general criteria for decisions regarding water supply projects, acquisition of
water rights and demand management measures.
B.2 Water Efficiency Planning
A water shortage often requires a relatively immediate response, which is intended to be
employed for a short duration. The response includes various adaptations to reduce
demand and/or increase supplies. This differs from water conservation and efficiency
efforts guided by the Water Efficiency Plan (WEP) in several ways.
WEP is meant to provide long-term demand reduction to increase resiliency to changing
climate and increase awareness and education amongst Utilities’ customer base. The
WEP is integrated into Utilities’ water resources planning, specifically the WSDMP. The
focus areas within the WEP address codes, programs, incentives, planning and other
work that result ongoing and persistent water conservation and efficiency.
The WEP is currently updated at least every seven years. Future updates to the WEP
should consider long-term strategies for water shortage mitigation, including but not
limited to:
• Water budgets
• Irrigation codes that require efficient watering best practices such as:
o Seasonal watering windows
o Minimization of daytime watering
o Minimization of overwatering
Utilities Water Conservation Department began its efforts in 1977. In 1999, it began the
Sprinkler Audit Program, which was then followed by several education programs,
rebates and other incentives for customers to reduce their use with improved efficiency
and greater conservation. In addition to the WEP, several codes exist that help mitigate
water shortages and promote ongoing and long-term water efficiency and conservation.
B.3 Other Water and Emergency Policies
Several City policies and plans relate to the WSAP. Below is a list of current sections of
the City Code that should be considered during a water shortage or when amending and
EXHIBIT B
Fort Collins Utilities 44 2020 Water Shortage Action Plan (WSAP)
updating policies and plans, including the WSAP, to ensure consistency and
cohesiveness.
o City Code Section 26-166 (Waste of water prohibited)
o Section 26-167 (Water supply shortage response, emergency restrictions)
o Section 26-168 (Obligation to comply, penalties)
B.4 Emergency Planning
Many emergency plans are not made public for safety and security reasons. For purpose
of the WSAP, it’s important to know that these plans exist and may be enacted prior to or
during a water shortage, depending on the scenario.
Utilities Water Production Division maintains jurisdiction over various emergency
operation plans:
• Emergency Response Plan (ERP) / Emergency Operations Plan (EOP)
• ERP Appendix or Checklists for response to natural and manmade hazards
• Dam Emergency Action Plans
• Division of Drinking Water Emergency Notification Plan
• Hazard Mitigation Plans
• Continuity of Operations Plans (COOPs) / Continuity of Government Plans
(COGs)/ Business Continuity Plans
• Water Outage / Emergency Drinking Water Plans
Utilities Water Quality Services’ Spill Response Plan outlines actions and communication
procedures when a contaminate threatens the Poudre River.
Emergency operation plans are managed by Larimer County Office of Emergency
Management, City of Fort Collins’ Emergency Preparedness and Security Department,
Poudre Fire Authority Office of Emergency Management and/or others who would
respond to an emergency related to a water shortage.
EXHIBIT B
Fort Collins Utilities 45 2020 Water Shortage Action Plan (WSAP)
Appendix C Historical Shortage Planning and
Events
C.1 Timeline of Shortage Planning Efforts
Ordinance 112, 118 and 135, 2002
Between July and September 2002, multiple ordinances were adopted, each amending
the previous ordinance to allow for greater lawn watering restrictions. In September
2002, City Council passed an ordinance limiting lawn watering to once per week and no
watering between the hours of 10 a.m. and 6 p.m.
Ordinance 048, 2003
Beginning in April 2003, Ordinance 048, 2003, was adopted by City Council to respond
to the persistent drought that began in 2002 and continued into 2003 in Fort Collins and
the much of the region. The Water Supply Shortage Response Plan (WSSRP) was
designed to respond to four levels of water shortage with a list of appropriate restrictions
that included many more outdoor water use restrictions for each response level, beyond
what was previously just lawn watering restrictions. The projected water supply
shortages adopted for each level are:
Response Level I: 1-10%
Response Level II: 11-20%
Response Level III: 21-30%
Response Level IV: Greater than 30%
Ordinance 047, 2013
In preparing for the potential of moving to Response Level II or higher, City Council
adopted Ordinance 047, 2013 in March 2013, which added rate increases starting at
Response Level II and included some additional, minor amendments. The rate increase
applied to all water rates and attempt to maintain revenues at the current budgeted level
for each possible response level, since the water rate adjustments are based on a
percent reduction in demand. Ordinance 047, 2013 also increases the Excess Water
Use Surcharge for each response level beginning with Response Level I.
In addition to the rate adjustments, Ordinance 047, 2013 included two amendments to
Ordinance 048, 2003. One changes the definition and use of “water fountains” and the
other involves changes to the terms of permits for large acreage and parks and
athletic/playing fields. The definition of “water fountain” was changed to “water feature,”
a more comprehensive term. The definition was modified to apply to both public and
private water features and to exclude water features that are part of a swimming pool.
The proposed restrictions allow the use of both public and private water features at
Response Levels I and II and prohibit them for Response Levels III and IV. Ordinance
047, 2013 removed the restriction on irrigating parks and public athletic/playing fields
Tuesday through Thursday for Response Levels II and III and removes the same
restriction on irrigating private property of four acres or more for Response Level II.
EXHIBIT B
Fort Collins Utilities 46 2020 Water Shortage Action Plan (WSAP)
Ordinance 88, 2014
Additional changes were made following the 2013 shortage and adopted in July 2014.
These changes were minor, but numerous and included changing the violation from a
criminal to civil infraction, adjusting the response levels for certain water restrictions,
resulting in either less or more restrictive use.
C.2 Historical Water Shortage Events
Utilities has formally declared two water shortages – 2002 and 2013. There is limited
historical information and data suggesting that water shortages have occurred in Fort
Collins in the past, but only two have occurred since a formal process and plan has been
adopted by City Council.
2002/03 Water Shortage
Drought conditions were severe in 2002 across Colorado and much of the western
United States. The Poudre River produced runoff of only about 30% of average, which is
the lowest runoff since records began in 1884. This followed two dry years when runoff
was about 70% of average. In addition, Northern Water, which allocates CBT quotas,
gave an initial 2003 quota of 30%, compared to a 70% quota provided in 2002.
Although Utilities was able to meet water demands for 2002, the severe drought raised
many concerns about the effect it would have on supplies for 2003 and beyond. Water
savings resulting from restrictions and other water conservation efforts were carried over
for use during 2003.
In March of 2003 the area received significant snowpack and Northern Water issued a
50% quota in April 2003, which lessened the shortage. A formal declaration date, stating
that restrictions were over, is unknown. Restrictions resulted in an estimated reduction in
expected use of about 18%.
EXHIBIT B
Fort Collins Utilities 47 2020 Water Shortage Action Plan (WSAP)
2013 Water Shortage
The 2013 water shortage was a result of water quality and quantity issues that
necessitated the declaration of a Level I water shortage response for two months – April
1, 2013, to June 1, 2013. Utilities was unsure how much water they would receive from
CBT at Horsetooth and there were water quality concerns for the Poudre River water
supply following two fires within this Poudre River watershed ignited in 2012 – the
Hewlett Fire in May and the High Park Fire in June – burning over 94,000 acres in total
(about 10% of the watershed). Rain events over the burn areas led to large amount of
ash, sediment and debris deposited in the Poudre River, making it difficult to treat and
deliver water from this source.
June-September 2012: Utilities relied solely on CBT supplies.
October 2012: Utilities started to blend CBT and Poudre River water to respond to
variability in sedimentation.
March 2013: Outlook for the western U.S. forecasted that drought would persist or
intensify through the spring of 2013.
April 1, 2013: Given the uncertainties and outlook, the City declared Level I water
restrictions in order to prepare for a low CBT quota, which wouldn’t be issued until mid-
April, and respond to the Poudre River water treatment challenges.
April 12, 2013: A 60% CBT quota was issued by Northern Water, which was insufficient
to meet the carryover goals for 2014 supplies.
May 2013: A significant increase in mountain snowpack occurred that resulted in
additional Horsetooth Reservoir supplies. Most of these additional supplies were from
the unexpected pumping of Windy Gap water and an increase in CBT water
appropriations from the North Poudre Irrigation Company.
June 1, 2013: Declaration terminating water restrictions. The graph below illustrates the
increase in CBT supplies and the relationship to a 7,500 acre-feet carryover target that
determined the termination of the water restrictions.
EXHIBIT B
Fort Collins Utilities 48 2020 Water Shortage Action Plan (WSAP)
These additional Horsetooth supplies allowed Utilities to:
• Meet remaining 2013 water demands, even with a hot, dry summer.
• Achieve the carryover goal of having approximately 7,500 acre-feet of water in
storage in the CBT system for use in 2014.
• Not require taking additional supplies from the fire-impacted Poudre River.
Mitigation Measures
Utilities spent 2012 and 2013 responding to
expected increases to sediment levels and
preparing for mitigation. The sedimentation issues
at the treatment facility were mainly due to the
variability of the sediment concentration.
Whenever there were flow changes in the river,
the sediment and subsequent turbidity changes. A
pre-sedimentation basin was designed and
constructed to mitigate the variation in the river
water quality before it reaches Utilities’
infrastructure. The basin allowed Utilities to
manage raw water from the Poudre River during
times of high sediment that naturally occur during
spring snowmelt and runoff.
Construction of Pre-Sedimentation Basin,
March 2013
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
1-Apr 12-Apr 8-May 1-Jun
Carryover Amount (acre-feet)
Date
City of Fort Collins - Carryover Target Progression
Current Carryover Amount Carryover Shortage
50% CBT
Quota
60% CBT
Quota
NPIC
Increases
Reuse Plan
Increases
EXHIBIT B
Fort Collins Utilities 49 2020 Water Shortage Action Plan (WSAP)
In addition to the basin, the Water Treatment Facility modified the treatment processes
to address the challenges with variability of the river’s water quality. This included:
1) Adding oxidation for enhanced coagulation and taste and odor control
2) Monitoring additional raw water
3) Increasing pilot plant activity
Water quality monitoring infrastructure was enhanced in 2012 by adding two rainfall
gauges and one water quality gauge in the Poudre Canyon, giving the treatment facility
more information about the water quality and amount of water in the river. Two more
water quality monitoring instruments were installed in April 2013. The gauges enable
better understanding of how storms and runoff events will affect water quality.
Response Effort
An educational approach was taken to water restrictions, rather than issuing citations to
customers. Utilities worked to engage and maintain the willing cooperation and support
of customers.
One full-time Water Conservation employee issued permits and responded to complaints
during the water shortage. In total 191 permits were issued, and 53 complaints were
received, but no citations were ever issued.
The graph below illustrates the water savings during the water restriction period of April
1 through May 31, 2013. Although the wet, cool weather during this period may have
been a large factor, water use was significantly lower than average and modeled
expected use.
Expected Use
Average Use
Actual Use
0
500
1,000
1,500
2,000
2,500
3,000
3,500
4,000
4,500
Water Use (acre-feet)
Water Restriction Savings
→ 897 acre-ft Saved from Average
→ 22% Below Average
→ 711 acre-ft Saved from Expected
→ 18% Below Expected
April 1 Through May 31, 2013
EXHIBIT B
Fort Collins Utilities 50 2020 Water Shortage Action Plan (WSAP)
Appendix D Profile of Existing
System
D.1 Service Area and Customer Profile
Fort Collins residents and businesses receive treated water from various water
providers, the largest of which is Utilities. There are 134,000 Utilities water customers,
which account for about 75% of Fort Collins residents and businesses.
In 2018, there were 32,900 residential accounts (single-family, duplex, and multifamily)
and 2,800 commercial accounts (businesses, institutions and irrigation). Currently,
Utilities delivers an average of approximately 24,000 acre-feet per year (21.4 million
gallons per day) to its treated water customers. Utilities has approximately 5,000 acre-
feet per year (4.5 million gallons per day) of treated and other raw water delivery
obligations to other entities. The primary factor that affects demands is the weather.
Annual water demands from Utilities’ customers can vary by around 10% above or below
projected annual use depending on the local temperatures and precipitation.
The Utilities’ service area population continues to grow; however, the use per capita has
become much more efficient over the last few decades. Utilities water customers used
143 gallons per capita per day in 2018. That’s down 32% since 2000 when all
customers’ use averaged 211 gallons per person per day.
EXHIBIT B
Fort Collins Utilities 51 2020 Water Shortage Action Plan (WSAP)
In 2018 the average monthly use for residential and commercial accounts show
seasonal and outdoor use varies significantly compared to winter months; accounting for
40% of the total annual water use.
EXHIBIT B
Fort Collins Utilities 52 2020 Water Shortage Action Plan (WSAP)
EXHIBIT B
Fort Collins Utilities 53 2020 Water Shortage Action Plan (WSAP)
Existing Supplies
Utilities receives raw surface water from two main sources, the Poudre River and
Horsetooth (which delivers waters available to Utilities from both the CBT project and
Windy Gap). On average, each source provides about half of the supplies used to meet
Utilities’ customer treated water demands. Utilities also uses transbasin water from the
Michigan River that is conveyed to the Poudre River via the Michigan Ditch, as well as
transmountain water through its ownership of shares in the Water Supply and Storage
Company.
Utilities’ Horsetooth supplies can be taken directly into the treatment facility, whereas the
Poudre River supplies must be delivered via two different pipelines. The management of
this system has allowed for flexibility to mitigate water quality issues by mixing these
sources at different times of the year to meet customer demands and water quality
requirements.
Utilities also rents water to local agriculture users in years when projections verify that
supplies will be in excess of demands and maximum reservoir storage capacity.
Because of system capacity constraints, legal constraints, and annual yield variations,
the amount available to meet treated water demands varies. Utilities’ water supplies can
meet an average annual treated water demand of approximately 30,400 acre-feet during
a period that includes a 1-in-50 drought. During droughts that are more severe than 1-in-
50, conservation measures or restrictions may need to be implemented to reduce
demand levels to meet the available supplies.
D 1.1 Poudre River Sources
Utilities has five senior direct flow water rights decrees on the Poudre River that allow
Utilities to divert water into the Fort Collins Pipeline year-round. These decrees are very
senior and are available to Utilities most of the time. The yields are fairly constant and do
not vary significantly from wet to dry years.
Utilities also owns and has changed to municipal use shares in several of the irrigation
canal and reservoir companies that are in and around Fort Collins, which provide other
Poudre River sources. The yields from these changed irrigation rights can vary
significantly from wet to dry years. However, without additional Poudre basin storage,
the ability to use these sources is limited. The proposed Halligan Reservoir enlargement
will significantly improve the usefulness of these water rights.
Finally, Utilities has several junior pipeline decrees that allow Utilities to divert water into
the Fort Collins Pipeline year-round. These junior decrees are typically only in priority
during the peak runoff period and in very dry years; Utilities may not be able to divert any
water under these rights.
D.1.2 Joe Wright Reservoir-Michigan River System
The Joe Wright Reservoir-Michigan Ditch System is another important source of water
for Utilities. This system, using the Michigan Ditch, diverts water from the Michigan River
basin into the Poudre River basin through Joe Wright Reservoir. The reservoir can store
Michigan Ditch diversions and water from Joe Wright Creek. To ensure that the Michigan
Ditch system can continue to operate even when there is a call placed on the Michigan
River that is senior to Utilities’ Michigan Ditch water rights, Utilities owns rights to water
in Meadow Creek Reservoir. This reservoir is located in the Michigan River basin and
EXHIBIT B
Fort Collins Utilities 54 2020 Water Shortage Action Plan (WSAP)
water can be released from the reservoir to allow the Michigan Ditch to continue to divert
water. Even with Meadow Creek Reservoir, the yields from this system can vary
considerably from wet to dry years.
D.1.3 CBT and Windy Gap Supplies
Northern Water manages and operates both the CBT and Windy Gap projects, which
can be delivered out of Horsetooth. Utilities owns 18,855 units of CBT and these units
typically deliver between a half to a full acre-foot per unit. Utilities also owns 3,564
shares of the North Poudre Irrigation Company, each of which includes four CBT units,
though Utilities typically receives less water per unit from them due to assumed losses in
the North Poudre Irrigation Company system.
Utilities also has a contractual right to annually receive 4,200 acre-feet of Windy Gap
water through the Reuse Plan. The Windy Gap system has a junior water right and there
is no dedicated storage to manage this water. The Windy Gap Firming Project is
expected to improve the reliability of this supply.
EXHIBIT B
Fort Collins Utilities 55 2020 Water Shortage Action Plan (WSAP)
Appendix E Water Supply
Vulnerability Assessment
Utilities conducted a Water Supply Vulnerability Study (Study) in 2018-20205. The study
evaluated thousands of supply and demand scenarios including the potential effects
from changing climate. The model indicated that increased temperature and/or
decreased precipitation could result in more frequent water shortages than previously
experienced. The modeling for the study needs additional refinement in order to evaluate
impacts to water supplies resulting from various action level restrictions and other
demand and supply-side responses.
Impacts of changing climate further the importance for water shortage action planning
and highlight the need for long-term responses, as well as both increasing supplies and
improving efficiency during non-water shortage years.
Improving supply vulnerabilities - Halligan Reservoir
Utilities has been pursuing the enlargement of
Halligan Reservoir through a federal permitting
process since 2006. Additional storage in an enlarged
Halligan Reservoir would reduce the frequency and
severity of water restrictions during droughts.
An enlarged Halligan Reservoir will help meet most of
Utilities’ future projected water demands, while
maintaining this same level of service. Our current
treated water firm yield (amount of demand that can
be met through the 1-in-50 drought while maintaining
a 20% storage reserve) without an enlarged Halligan
Reservoir is about 30,400 acre-feet. Once built, an
enlarged Halligan Reservoir will help meet Utilities’
projected future treated water demands of about 38,400 acre-feet. So roughly 8,000
acre-feet (or about 20%) of Utilities’ projected future demands will be firmly provided with
the addition of an enlarged Halligan Reservoir.
5
The Water Supply Vulnerability Study can be made available, upon request, by contacting the Fort Collins
Utilities Water Resources Division.
Halligan Reservoir
EXHIBIT B
Fines per Violation
$250-1,000 $500-1,000 $500-1,000 $250-1,000
Water Rate
Adjust Water Rates Not applicable No adjustment
20% increase to
volumetric charges
only, excluding
IQAP tier 1
30% increase to
volumetric charges
only, excluding
IQAP tier 1
Rate increases will
be requested by
City Ordinance, as
necessary
EXHIBIT B
watering on
Monday and
between the
hours of 10 a.m.
and 6 p.m.
Water on one
selected day. No
watering Monday
thru Thursday and
between the hours
of 10 a.m. and 6
p.m.
No exceptions
EXHIBIT B
implemented. No
filling of empty
pools
Toys not allowed.
Pools are
unrestricted, if filled
before date
restrictions were
implemented. No
filling of empty
pools
Misting Devices
Limit use to only
when temperatures
are extreme and
misted areas are
occupied
Unrestricted -
consider water
shortage watch
measure
Not allowed Not allowed
EXHIBIT B
Collector Street
Sweeping will be
reduced to 1x a
month and all other
sweeping restricted
to essential street
sweeping.
Whenever possible,
dry methods must
be deployed first
Hydrant Flushing
and Testing
No more than
normal operating
schedule and critical
situations
Limited to critical
situations as
approved by
Utilities' Executive
Director
Limited to critical
situations as
approved by
Utilities' Executive
Director
Limited to critical
situations as
approved by
Utilities' Executive
Director
EXHIBIT B
health or safety
reasons
Not allowed unless
approved by the
City Manager for
health or safety
reasons
Dealership Vehicle
Washing
As needed Once per week Upon Sale Upon Sale
Spraying
Impervious
Surfaces
Whenever possible
deploy dry methods
first
Not allowed,
except for
essential power
washing.
Whenever
possible, dry
Not allowed, except
for essential power
washing. Whenever
possible, dry
methods must be
deployed first.
Not allowed, except
for essential power
washing. Whenever
possible, dry
methods must be
deployed first.
EXHIBIT B
to address other
unique scenarios
Food Production
Limit watering to two
days per week and
not between 10 a.m.
and 6 p.m., and by
hand or by drip
system at any time
May be watered
by sprinkler on
Residential (even)
- Th & Sun
Residential (odd)
- Wed & Sat
multifamily &
Commercial - Tue
& Fri., other than
between 10 a.m.
and 6 p.m., and
by hand or by drip
system at anytime
May be watered by
sprinkler on
Residential (even) -
Sun
Residential (odd) -
Sat
multifamily &
Commercial – Fri.,
other than between
10 a.m. and 6 p.m.
May be watered
only by hand, or
drip system at
anytime
May be watered
only by hand, or
drip system at any
time
EXHIBIT B
Limit to two days per
week
Residential (even)
- Th & Sun
Residential (odd)
- Wed & Sat
Multifamily &
Commercial - Tue
& Fri.
Residential (even) -
Sun
Residential (odd) -
Sat
Multifamily &
Commercial – Fri.
Not allowed
EXHIBIT B