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  • Writer's pictureMark L. Johnson

DAWS Flaws

Tony Davis wrote an excellent article regarding the Marana DAWS Modification Application (Application) that headlined in today's Arizona Daily Star (Sunday 1/14/24). You can download and read the full text of the article by clicking on the link below.

Tucson Daily Star Article by Tony Davis-Marana DAWS-1-14-24
Download PDF • 63KB

The article includes input from Marana Water (MW), Kyle Water Center (ASU), Central Arizona Groundwater Replenishment District (CAGRD), Tortolita Alliance (TA) and other water agency and water resource experts. It provides additional insight and support for some of the key TA objections including: (1) 1,000' Depth To Groundwater Criteria, (2) Safe Yield Goal Demonstration, (3) Population & Demand Projections, (4) Colorado River Supply, (5) Groundwater Quality and (6) Transparency. These are further elaborated below.


Article Clarification-Long-term, permanent water supplies.

From 2004-2016, I served as Director of Engineering for the Coachella Valley Water District (CVWD). CVWD's service area is located in the western portion of the Sonoran Desert in southern California from the Salton Sea to Palm Springs. CVWD services included domestic water, wastewater, agricultural irrigation, stormwater, recycled wastewater and groundwater recharge. The total water demand for all services in 2010 was 678,600 acre-feet/year (AFY) [234 times MW's 2021 water demands of 2,900 AFY!]. CVWD has secure, long-term, permanent water supplies totaling 682,600 AFY. The sources of supply included the Colorado River, CA State Water Project (SWP) and Recycled Wastewater (Effluent). One of my many duties at CVWD was water supply planning and water supply acquisition to ensure future water demand could be achieved. In the period 2010-2012, I negotiated and acquired the permanent transfer of 33,000 AFY of SWP water from three northern CA irrigation districts at a cost of $100 million. The water is conveyed via the SWP aqueduct from northern CA to the Coachella Valley. If I had approached the CVWD Board and proposed to spend $100 million for non-permanent supplies that were only available for 25 years---I would have been laughed out of the Board room. That is the story behind the quote in the article.


Please Send An Objection Letter

Although the article suggests the Marana DAWS Modification is almost a done deal from a legal requirement perspective, it is not a done deal from our practical and prudent water supply planning perspective. Except for TA's efforts, the community has not been informed or had the opportunity to provide input on this generational issue. Therefore, we urge all concerned Marana residents to write and Objection Letter and request an Administrative Hearing as outlined in our last blog Marana DAWS Modification-Reminder-Objection Letter.


Article Key Objection Points

1,000' Depth To Groundwater Criteria

The Kyle Water Center researchers (also former ADWR officials) confirm that the 1,000' Depth To Groundwater criteria is "arbitrary" and "not based on hydrological principles of the sustainable amount of groundwater that an aquifer can yield". Incredibly, ADWR continues to utilized this non-scientific criteria to make assured water supply determinations.

Safe Yield Goal Demonstration

Tucson Active Management Area (TAMA) goal is to achieve and sustain safe yield, which means that water leaving the aquifer must be replaced by replenishment water coming into the aquifer. However, the Application provides no evidence that safe yield can be achieved---just a bunch of promises.

  • Central Arizona Groundwater Replenishment District (CAGRD) admits that it does not have long-term permanent water supply sources and does "rolling 20-year" water supply planning.

  • Marana and others have stated that the 800' depth to groundwater level identified in the groundwater model will never happen. Use the groundwater model, simulate replenishment in the impact area and prove it to us!

  • The new Hobbs budget has cut the proposed $333 million investment in the New Water plan (desalination or other) to $33 million! Therefore, new long-term permanent supplies for CAGRD's portfolio are a long way off.

Marana Population/Demand Projections-Constantly Changing

Water demands are projected based on population. However, we get different population projections from Marana:

  • Mayor stated that the population would reach 100,000 by 2028

  • Article states Marana has indicated a population of 72,000 in 10-years (2032)

  • Marana Water Master Plan (2010)-shows population of 141,210 in 2030

Which is the correct number? Marana needs to provide a consistent and accurate projection of population and water demands and utilize the correct information for this application.

Colorado River Supply

ADWR accepts the fact that Colorado River supplies are being impacted and have shortened the DAWS time period from 20 to 10 years. This is a good thing but applying a reliability factor of 80% to Marana's CAP supply is an additional factor-of-safety and should be applied as part of this application.

Groundwater Quality

Concerns were raised about the mixing of non-native replenishment water in the aquifer and the potential adverse impacts. The article did not mention the contamination of the aquifer with "forever chemicals" which must also be addressed.

Non-Transparent Process

The Marana DAWS Modification is one of the most important issues impacting the community in a generation and the entire process has been done with little public knowledge, education and participation. It is shameful.

  • Marana and the Arizona Department of Water Resources (ADWR) have been working on the Marana DAWS Modification application for 18+ months, yet one cannot find any relevant information regarding the application on either website.

  • Public notice of a very short (22 days) objection period was noticed in a local boutique publication called the Daily Territorial that most people are not even aware of.

  • If not for TA's Public Record Requests (PRRs) and reporting, it is doubtful that the community, or local newspapers for that matter, would have been aware of the application until the process was over.

  • ADWR docket process for filing letters and objections is archaic. It is amazing how a state agency like the Arizona Corporation Commission can have a robust electronic docket filing and search system and another agency like ADWR does not.


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