Franklin Drinking Water October 2014 FRANKLIN’s WATER TREATMENT PLANT: FINANCIAL ANALYSIS, EXTERNALITIES, RESPONSIBLE MANAGEMENT of RIVER RESOURCES and RATEPAYER’S MONEY _______________________________________ Energy and Water Economics: William W. Wade, Ph.D Brian Roach, Ph. D Hydrological Analysis Prepared by: October 31, 2014 Analysis Commissioned by HRWA Policy Significance of PowerPoint Slides: Franklin’s Water Treatment Plant -Financial Analysis, Externalities, Responsible Management of River Resources and Ratepayers’ Money October 31, 2014 William W. Wade, Water Resource Economist [email protected] Policy-Relevant Conclusion Franklin’s proposed new WTP makes no financial sense, is not needed to meet Franklin’s future demand, and has not been shown to be needed to increase supply reliability. Harpeth instream flows provide services to the community of high economic value that are ignored by City of Franklin submittals. City has not and cannot show that the project would not cause a significant permanent loss of economic values related to the Harpeth. My findings are that the investment is a waste of ratepayers’ and City money. My expert opinion is that overlooked economic values of other uses of the river are substantial and missing from the record. Franklin is a special place whose highly educated residents are aware of factors that govern their Quality of Life. They deserve state-of-the-art Harpeth resource management planning. City submittals do not provide this, including its IWRP. HVUD is a financially feasible existing alternative supply, upgraded and enlarged to meet latest Safe Drinking Water Act rules; HVUD supplies water reliably to most of Williamson County. HVUD is the lower cost, reasonable supply alternative. The City’s planned (WTP) is not accurately described by Mayor Moore and City Administrator Stuckey as a 2.6 MGD plant. The small and variable flows of the river reveal that it is not financially capable of recovering its high capital investment. It would result in unnecessary high rate increases to the detriment of ratepayers, particularly lower income ratepayers. State Regional Water Supply Planning policy directs Franklin’s future water supply to increased Cumberland deliveries. The Harpeth River should be retired as a water supply; the time has come for state and local leaders to acknowledge that its other uses are more valuable to residents in 2014 than the unneeded water supply plant. State antidegradation rules require that Franklin demonstrate no loss of resource values or choose the HVUD alternative. Franklin has never and cannot demonstrate “no loss of resource values.” The Harpeth River “is necessary to accommodate important economic and social development in the area.” City leadership has ignored, but TDEC must consider the Harpeth’s other values under Chapter 0400-40-03.06 of the antidegradation policy. 1 1 Proposed Project City of Franklin’s existing 2.1 MGD water treatment plant cannot meet the requirements of the Long Term 2 Enhanced SW Treatment Rule (LT2) and the Stage 2 Disinfectants and Disinfection Byproducts Rules (Stage 2 DBP rule) in the Safe Drinking Water Act to provide additional protection from pathogens and reduce disinfection byproducts. It must be retired after more than 50 years of good service. Franklin water supplies have been provided primarily by HVUD for years, which will continue to supply over 70 % of Franklin’s water from the Cumberland River, even with the proposed WTP. In recent years, the split between the two shows: WTP ~25% from Harpeth River; (~19% July – October) HVUD ~75% from Cumberland River. Franklin’s economic and population growth of recent decades – 70% of people living in Franklin today were not here in 1990 – has been supported by HVUD’s growth in capacity – not the Harpeth River. The Harpeth is the same small river it was when the first WTP was built in the 1950s to serve a small water demand. It is too small and too unreliable year-toyear and season-to-season to matter to Franklin’s economic and population growth. The size of the proposed WTP is too large and expensive to be financially feasible on the Harpeth, due to insufficient storage capacity. City Water Department, Mayor and City Administrator want to build a new larger WTP. Both Mayor Moore and City Administrator Eric Stuckey in op-eds run in The Tennessean and at the TDEC October Hearing claim the plant to have a 2.6 MGD capacity. SSR’s submitted Preliminary Engineering Report (PER) refers to the plant as a “firm” 2.6 MGD capacity plant. In fact, the analysis provided by SSR in August 2014 proves that the “firm” 2.6 WTP is a 4.0 built capacity plant. FN2 to SSR PER Table 7.1 states “[p]roduction capacity with all units running for a 2.6 MGD . . . firm rated facility is 4.0 MGD. . . . Results of SSR’s flow analysis reveal annual water withdrawal rates in excess 3.5 MGD; SSR’s reported average water treatment rate is 2.84 MGD, > 2.6 MGD. Whether the Mayor and City Administrator speak in error, or seek to mislead the public and TDEC, is unknown. The plant presented to TDEC for its ARAP is a 4.0 MGD capacity built plant, mislabeled 2.6 “firm” capacity, and shown by SSR to withdraw amounts greater than 3.5 MGD. 2 My analysis shows that the SSR designed 4.0 MGD WTP will be able to produce between 313 and 371 MG a year more than the true 2.6 MGD capacity plant, at the 5% to 95% likely range of production; 341 MG at the 50 %ile. (See slides for details.) That is a great deal more water withdrawal than the claimed 2.6 MGD plant could withdraw from the Harpeth. My financial analysis examined both: A true 2.6 MGD capacity WTP; The 4.0 MGD plant that SSR actually designed. The investment costs in the record for the plant, including the expenditures for the improved 113 MG storage reservoir, total $16.3 Million, ~22% of which has been expended; the remaining ~78% is scheduled to be expended over 2015 & 2016. 2 The $11.7 million investment presented to the public is misleading, omitting the cost of the reservoir and ongoing design studies. Reasonable alternative: HVUD 100% The reasonable alternative – the financially preferred alternative – to the proposed WTP is to shut down the existing plant and increase HVUD purchases to meet 100 % of Franklin’s demand. HVUD can supply 100% of Franklin’s growing demand, which it has been doing since 1983 when the city first connected to HVUD. HVUD reliably provides drinking water to practically all of Williamson County. HVUD has invested $ tens of millions since the 2010 flood. Upgraded treating capability to Bin 4, higher than SSR Bin 3 design for WTP, to meet LT2. (Bin treatment is defined in the SDWA based on level of microbial removal. A higher Bin number removes 10 times more.) Enhanced withdrawal, treatment and delivery redundancy in its system. City of Franklin presentations ignore HVUD’s upgrades, expansions and back-ups, instead speaking about the short outage during the 2010 flood, which has been remedied by redundant HVUD systems. 3 HVUD’s existing 2014 rate and its October 9, 2014 forecast of rates reflect the embedded cost of these upgrades. Their guiding rate forecast calls for 1.5% rate increases over the next 20 years. (See my remarks about HVUD’s rate forecast in PowerPoint slides.) Franklin’s rate consultant, Jackson Thornton, called for 3.5% rate increases 2015-2019 or 4.25%, 2016-2019, to pay for the City’s capital investment, increased debt service and water service operating costs related to the proposed new plant coming on-line, 2017. (Presentation to City of Franklin, July 10, 2014.) Financial analysis discussed below and detailed in the PowerPoint slides reveals that, indeed, 100% HVUD purchases is the better financial option for Franklin’s future water supplies. 3 SSR’s designed WTP cannot recover the $16.3 million investment because Harpeth flows are too variable year-to-year and season-to-season. Brief remarks about withdrawal amounts, variability and inadequate storage. The proposed 4.0 MGD plant will withdraw water during months with adequate flows that double typical existing production, contrary to public claims. The average annual production capacity of the existing 2.1 mgd plant over the 39 year Harpeth flow history is 695 MG; the 50% likely value of future production in the designed 4.0 mgd plant is 1,177 MG. Thus, the 50 %ile withdrawals are 69% higher than historic average withdrawals. (The range of the proposed withdrawals is in the PowerPoint.) The seasonal variability of Harpeth flows would require substantial storage to maintain economic production levels, August thru October. The 2012 reservoir upgrade provides grossly inadequate storage to provide reliable water Aug - Oct for the 4.0 MGD plant. 4.0 MGD WTP would require nearly 450 MG storage above minimum pool, according to AquAeTer; existing reservoir provides ~79 MG storage, 18% of needed storage. 4.0 MGD WTP provides only slightly more average water supplies, Aug – Oct, than the existing 2.1 MGD WTP. HVUD supply has been and will remain the future supplier of more than 80% of Franklin’s water supply during these months. (Based on the 39 year flow history.) 4 The Harpeth’s small size, wide seasonal flow variability and inadequate storage to offset the seasonal supply unreliability undermine the financial viability of the proposed new WTP. Financial analysis shows that new WTP is a waste of ratepayers’ money 4 E&WE conducted the first ever correct statistical analysis of the Harpeth’s flow variability to support my financial analysis of WTP expansion. SSR’s and CTE’s (2006) analysis, which the 2012 CDM IWRP adopted and relied on, are both single point evaluations as if the mean water production is sufficient to guide policy. Because the Harpeth flows vary substantially, year to year, single point — “mean”— results are not sufficient to guide policy, or responsible City financial evaluations. (See PowerPoint slides for description of approach.) The City’s current drinking water plant costs more to operate than purchasing all HVUD water based on actual costs recently provided for 2013 by Jackson Thornton: $3.90 per 1000 gallons versus $2.36 per 1000 gallons to purchase from HVUD. (See slides for details.) City-produced water is not lower cost than purchased HVUD water. Mr. Stuckey’s claim at the TDEC Hearing of $1.50 cost per 1000 gallons is not supported by either the 2011 or 2013 Jackson Thornton Cost of Water Service. The data for year-ending 2011 show $2.25 per 1000 gallons, compared to $1.94 for HVUD purchases. HVUD’s forecast for the 2014-2016 construction period to build the new WTP show that HVUD purchases will be significantly lower cost water than City-produced water. Losses over four years could total ~$2.0 million, even if Harpeth flows allow the WTP to operate in an optimistic range of 85% capacity. Financial results reported below deal with the proposed new plant with a start-up date of 2017 and do not include the ~$2.0 million losses from continued operation of the existing plant. Franklin’s proposed steep increases in retail rates can be avoided by shutting down water withdrawals from the Harpeth and buying all water from HVUD. The proposed City rate hikes will be detrimental to ratepayers, particularly lower income households. 5 My financial analysis of both the true 2.6 MGD capacity plant and SSR’s 4.0 MGD capacity plant (mistakenly called 2.6 firm capacity by SSR) reveals that the Harpeth is too small to comply economically with expensive capital investment and operating cost requirements needed to meet new Safe Drinking Water Act requirements. Yes, Virginia, economies of scale are an accurate economic doctrine. The true 2.6 MGD plant will produce water at higher cost than HVUD purchases based on HVUD’s guiding October 9, 2014 forecast. The 2.6 MGD WTP water production will cost more than HVUD purchased cost over the entire statistical range of Harpeth flows. It provides no savings to offset the $16.3 million investment. The Harpeth is too small and flows too variable to support the Mayor’s claimed 2.6 MGD WTP. This may be the reason that SSR reports results assuming 4.0 MGD capacity. The 4.0 MGD plant does not recover the investment cost. Although it can produce water at a lower cost than HVUD purchases for years of normal to wet flows in the Harpeth, over the 20-year capital investment recovery period the present value of accumulated savings (compared to HVUD) are too small to offset the $16.3 Million investment. The returns to investment are insufficient to recover the investment over the statistical range of outcomes. The present value 2014 (PV) of annual savings from the 4.0 MGD WTP compared to HVUD purchases over the 20-year investment period set by SSR shows: The PV of savings over the entire statistical range of 20-year flow sequences does not recoup the investment. PV of losses accruing to the $16.3 million investment range from ~ ($7.0) to ($11.0 million). Even at 5% likelihood of high flow rate, savings of 4.0 MGD plant do not provide a positive return on the investment. Investing $16.3 million in the new plant and reservoir is a waste of ratepayers’ money and a bad use of City money. The City has better uses for its money. 6 5 Overview of SSR cost deficiencies Cost information for the proposed plant that has been presented to City, TDEC and Aldermen is incomplete and misleading. SSR’s PER “Table 7.4 Cumulative Payback on 2.6 MGD Facility” compares incomplete costs of their designed WTP to full cost of HVUD purchase – a biased comparison. SSR operating costs include only electric power and chemicals costs and do not include ongoing plant operating costs related to labor, vehicles, insurance, etc. Jackson Thornton Cost of Service study for the city, 2014, shows these to be $1,010,381. SSR did not include annualized membrane, carbon, and UV bulbs replacement that total $145,566. These figures were in the spreadsheets provided by SSR that are the basis of their Preliminary Engineering Report, Aug. 2014. SSR ignores capital investments for the engineering design ($1.46 million) studies and the reservoir repair and upgrade ($2.95 million), which raise the investment cost from $11.7 million to $16.3 million. The annual capital recovery is $1,093,452, not $585,686 reported by SSR as debt service on Table 7.4 – nearly double the amount shown by SSR and consistent with estimates shown by Jackson Thornton’s “Projected Revenue Requirement.” SSR’s analysis was based on lower annual overall capital and operating costs, and did not work from the entire 39 years of Harpeth flow data. The range of outcomes to reflect the variable range in Harpeth flows is not presented. The annual net savings reported on SSR PER Table 7.4 do not exist when the results are corrected for missing costs, Harpeth flow variability, and HVUD’s guiding rate forecast in pace of an assumed 3% HVUD rate escalation. The present value of the annual net savings of the 4.0 WTP are insufficient to payback the $16.3 million investment based on the corrected capital and operating costs and the full use of the 39 year hydrologic variability, year to year, and month to month. 6 Franklin’s claimed redundancy rationale ignores established utility service reliability evaluation. City Administrator Eric Stuckey repeatedly claims that the new expensive WTP will provide Franklin “redundancy” to HVUD supply. The need is not proven. 7 Stuckey cites failures of other locale’s water distribution systems to claim a rationale to build the new WTP. Distribution failures in very old water systems across the country are irrelevant for a reason to build a water production facility. No evidence in the record documents any basis for the need for redundancy or cost to City water users avoided by the $16.3 million investment. No risk assessment of HVUD supply outage exists. No cost of supply disruption exists to justify the $16.3 million project to avoid the unestimated risk. Utility agencies track their supply reliability; for the power sector, this is a required metric, with 99.999 expected reliability. Supply reliability is an empirical measure of a utility’s ability to deliver uninterrupted service with established analytic methods and valuation metrics. It requires estimation of frequency, duration and severity of possible supply shortages. And the cost of such empirically expected events sufficient to justify the agency’s cost to avoid. In other words, the empirically estimated costs avoided by the $16.3 project investment, plus financially estimated losses reported above, would have to be larger – taking account of frequency, duration and severity of HVUD supply outage– based on HVUD’s upgraded system improvements since 2010. The City’s “redundancy” claim is without merit, without analytic support. No appropriate and required measures have been considered. I explained this technical deficiency to Mr. Stuckey in our February 28 meeting; yet, he continues to make the unsupported redundancy claim. (See Wade March 3, 2014 Memo to Mayor Ken Moore and City Administrator Eric Stuckey, “Talking Points from February 28, 2014, Meeting.” Discussion of reliability planning on p. 5-6.) 7 Economic analysis reveals that Franklin ignores established methods of evaluating water resource development Water supply planning must take account of the values of all services provided by the Harpeth River. This is established resource planning doctrine – everywhere. 8 In the 21st Century in Middle Tennessee, the services provided to the community by the Harpeth River are obviously more valuable than water withdrawals for urban water supplies—besides the fact that the project is not financially viable. TDEC’s decision regarding Franklin’s ARAP is a statewide policy issue of seminal importance. Franklin has never provided the necessary economic information to TDEC to prove that no economic values of Harpeth River services are impaired by water withdrawals. The total economic costs of resource use, not simply the City’s financial costs, must be quantified and included. This is standard water resource planning across the country. Franklin’s 2012 IWRP does not achieve this standard. (See Wade March 3, 2014 Memo to Mayor Ken Moore and City Administrator Eric Stuckey, “Talking Points from February 28, 2014, Meeting.” Discussion of shortcomings of the IWRP at p. 6-9.) Franklin’s evaluations have ignored the cost of externalities and opportunity losses since it began evaluating its WTP expansion in 2006. The cost of externalities caused by water withdrawals on Franklin’s Sewage Treatment Plant (STP) water quality problems downstream is missing from the record. Considering a $50-$75 million upgrade and expansion to the STP, economic commonsense requires knowledge of the related externalities of reduced or increased flows. Given the interrelationship between water withdrawals at the WTP and water quality problems downstream of the STP, regulatory decision commonsense requires knowledge of the related externalities of reduced or increased flows, governed by TDEC’s decision on Franklin’s ARAP. City and citizen opportunity losses caused by the City’s myopic management of the Harpeth as its (unnecessary) water supply have been ignored by the City and are not in the record. Spending $16.3 million to build a new, higher operating cost WTP will increase water rates and impose unnecessary hardship on lower income residents. Opportunity values related to enhancement of river overlooked by the City include: Gateway to Franklin Downtown at Franklin Pike River walks with greater visual access 9 Viewscapes to river in vicinity of Gateway at Franklin Pike Franklin Curb Appeal – High amenity value Visually induced development catalyzed by viewscapes Sales and property taxes related to development Enhancement of citizens’ quality of life Improved recreation access Improved habitat and wildlife/fish abundance City Administrator Stuckey identified wastewater assimilation as the most important service of the Harpeth in our February 28 meeting. The externality cost of water withdrawals remain missing from the record. Mayor Moore identified aesthetic and recreational values of the river as the second most important service of flows provided by the Harpeth. The opportunity value of shutting down the WTP and improving the amenity values of the river remain missing from the river. My professional opinion – in the absence of required research in the record – is that potential new government revenues to the City plus beneficial values to the citizens foregone by operation of Harpeth water withdrawals are larger than the substantial investment of the proposed WTP. City investment to improve attributes of the Harpeth River will justify the expenditure. Water supply development does not justify the $16.3 million investment. The highest and untapped best use at risk to increased degradation of the Harpeth is enhancement to transform the river into an accessible, scenic community resource that adds to citizens’ quality of life and the local economy. Improvement of the river, not increased withdrawals, is necessary to accommodate important economic and social development in the area. The financial losses related to building the plant are likely a moot point compared to a competent economic estimate of positive values of enhanced instream flows and mitigation of negative cost externalities to Franklin’s STP effluent treatment problem. These are missing from the record. 10 Franklin’s Water Treatment Plant: Financial Analysis, Externalities, Responsible Management of River Resources and Ratepayers’ Money Presentation to HWRA, TDEC & City of Franklin William W. Wade, Ph. D. Brian Roach, Ph. D. Energy and Water Economics October 31, 2014 Organization of Presentation 1 Established Principles Of Water Supply Planning In The 21st Century. 2 How Does EWE Analysis Differ From SSR, CDM, CTE (2006) and the EWE Prior (2006) Work? 3 How Big Is The Planned WTP? 4 Size Revealed by how “Firm” 2.6 WTP Performs Compared to “True” 2.6 WTP. 5 Financial Analysis of Franklin Investment Decision: Investment and Operating Costs. 6 Does Existing 2.1 MGD WTP Drinking Water Cost Less than HVUD? 7 What Are The Savings/(Cost) For Build Or Buy? Do The Savings Recover The Investment Cost? 8 Does City’s Redundancy Claim Justify The Plant Investment? 9 Incomplete Record Does Not Allow Responsible Decision. E&WE 2 1 Established Principles Of Water Supply Planning In The 21st Century E&WE 3 Franklin’s Situation (1) Existing 2.1 MGD Water Treatment Plant cannot meet Long Term 2 (LT2) Enhance SW Treatment Rule and must be retired. • WTP provided ~25% of water supply in recent years, < 20% July - October. • HVUD provided ~75% of water supply, >80% July - October. Harpeth River has water quality problems downstream of the STP, downstream of WTP intake, which reduces flows to STP. City Water Department, et al, want to build a new MGD plant, labeled by SSR as “firm” 2.6 MGD capacity; Mayor and City Administrator call it a 2.6 MGD WTP. • Plant is designed to meet EPA Bin 3 standards. Reservoir storage is too small to supplement Harpeth variability. E&WE 4 Franklin’s Situation (2) HVUD can supply 100% of Franklin’s growing demand and serves most of Williamson County. HVUD has invested $ tens of millions since the 2010 flood. • Upgraded treating capability to Bin 4, higher than SSR design for WTP, to meet LT2, etc. • Enhanced withdrawal, treatment and delivery redundancy in its system. HVUD connects to Franklin distribution system at 2 locations; 100% HVUD will increase Harpeth flows thru Franklin. • Provide more dilution for STP effluent; • Provide more instream flow for a variety of other services to E&WE community and habitat 5 Zen Thought Franklin was a town of about 5,500 when the City first withdrew water from the Harpeth in 1952. The Harpeth, a small river, was a good source for Franklin’s small water demand. Franklin has grown more than tenfold in recent decades, and will experience even more growth. The Harpeth remains the same small river it was in the 1950s. The Harpeth is too small to comply economically with expensive LT2 requirements. E&WE 6 “The times . . . They are a-changing.” -Bob Dylan 1 Changing Franklin demographic indicators reveal a city today way different from rest of state – and the past. 2 Established economic planning methods demand accounting of all Harpeth River services. • • 3 Not Just the financial cost of water supply options. Voters understand Harpeth’s values to Franklin. Changing Face of Franklin requires Harpeth River management to balance the values of all Harpeth River services. E&WE 7 Established Economic Planning Requires Measurement of Full Cost of Water. 100 Full Cost of Water 90 Full Economic Costs 80 Scale only illustrative 70 Largest Overlooked Element 60 50 40 Financial Costs 30 20 10 0 1 Capital Cost (Annualized cap recovery) Operating Cost E&WE Opportunity Cost Externalities 8 Opportunities Ignored: Beneficial values and government revenues omitted from City’s Analysis. Opportunity values related to enhancement of river: • Gateway to Franklin Downtown at Franklin Pike • River walks with greater visual access • Viewscapes to river in vicinity of Gateway at Franklin Pike • Franklin Curb Appeal – High amenity value • Visually induced development catalyzed by viewscapes • Sales and property taxes related to development • Enhancement of citizens’ quality of life • Improved recreation access • Improved habitat and wildlife/fish abundance • Any better use of City Money E&WE 9 Financial cost estimates alone are not sufficient decision criteria for water supply planning. Instream flows are essential for wastewater dilution. • Externalities cost of drinking water withdrawals is missing. Improved Harpeth quality has an opportunity value for Franklin residents and business. • Values of enhancement of the River are missing. Improved scenic values of the River will enhance curb appeal and economic development. • Opportunity value of increased government revenues is missing. Established water resource planning cannot ignore economic values of competing uses of the River. E&WE 10 2 How Does EWE Analysis Differ From SSR, Preliminary Engineering Report, Aug. 2014 CDM, IWRP 2012 CTE (2006) and EWE (Wade’s) Prior (2006) Work? No prior work correctly incorporates Harpeth flow variability. E&WE 11 First time ever correct statistical methods support financial analysis of WTP expansion. 1 2 Used AquAeTer’s 2014 hydrologic analysis of WTP production capacity for 2.1, 2.6 and 4.0 MGD plant capacity – with: • USGS daily Harpeth flows thru September, 2014; • Storage capacity – 113 MG, with 34.25 MG minimum pool; • 8 MGD pump withdrawal capacity; • 10 cfs floor, 15% maximum withdrawal. Sampled 10,000 20-year sequences of annual production capacity for 2.6 and 4.0 MGD plants from 39 historic years: • Calculated annual costs of producing drinking water for 2.6 mgd and 4.0 mgd WTPs; • Calculated statistical distribution of PV 20-year annual costs; • Compared these to PV cost with HVUD’s rate forecast; • Conducted standard financial evaluations of City’s investment 12 E&WE decision. Harpeth Flow are variable and must be analyzed as a statistical range of outcomes. 1. From the 39-year daily flow history, we sampled 20-year annual sequences of plant production based on AquAeTer’s modeling of plant production at 2.6 and 4.0 MGD Capacity -- 10,000 times. 2. For each year of each 20-year sample, we calculated the cost of operating the plant as the sum of the fixed and variable (water production) costs, based on corrected SSR costs. 3. We discounted each year of the sequence with the 5% discount rate. 4. We summed the discounted annual values to equal the total discounted present value of the costs for that 20-year sequence. 5. Thus, we obtained 10,000 present value costs of 20-year sequences. 6. We sorted the 10,000 present values in Excel from smallest to largest. 7. We truncated the distribution to yield the lowest, 1%, 5%, 10%, 25%, 50%, 75%, 90%, 95%, 99%, and highest values. 8. Financial comparisons with HVUD purchases are presented for the 5%, 25%, 50%, 75%, and 95% percentiles. E&WE 13 3 How Big Is The Planned WTP? “Firm” 2.6 WTP is 4.0 Built Capacity. 4 How Does 4.0 MGD Perform Compared to “True” 2.6 WTP? E&WE 14 SSR “Firm” 2.6 WTP is 4.0 WTP capacity. July-Oct supply capacity limited by flows. Monthly Supply Potential: Existing and Alternative WTP Capacity 4.5 Why does 4 mgd plant perform no Why does 4.02.6 WTP better than plant? perform no better than 2.6 WTP? 4.0 3.5 3.0 2.5 2.0 1.5 1.0 Source: Source: AquAeTer AquAeTersource Jan Feb Mar Apr May 2.1 WTP E&WE Jun Jul True 2.6 WTP Aug Sept Oct Nov Dec 4.0 WTP Existing and expanded WTPs’ supply limited by inadequate storage. 15 The 4.0 WTP is not matched to sufficient storage to improve July - Oct. reliability. MG Storage above Minimum pool to Produce Design Capacity. 450 400 350 300 250 200 150 100 50 0 2.1 E&WE 2.6 4.0 Actual* Source: AquAeTer; *Actual = 113 less 34 MG minimum storage reported by SSR. 16 Expanded WTP capacity does not improve reliability during peak monthly demands. Average Monthly Demand & Average Supply: 14.0 13.0 12.0 11.0 10.0 9.0 8.0 7.0 6.0 5.0 4.0 3.0 2.0 1.0 Jan Feb Mar 2.1 WTP Apr May True 2.6 WTP Jun Jul 4.0 WTP Aug Sept Oct Nov Dec AVG Monthly Demand IWRP Source: Plant supplies: AquAeTer; Demand is mid point of IWRP forecast. E&WE 17 True 2.6 & 4.0 MGD WTP Aug-Oct reliance on HVUD – 86-88%. % of Average IWRP outyear demand met by monthly average Supply: True 2.6 WTP v. 4.0 WTP % HVUD HVUD 100% 90% 80% Annual Average % HVUD: True 2.6 = 78% YR 4.0 WTP = 70% YR 70% 60% 50% 40% Jan Feb Mar Apr May Jun True 2.6 WTP E&WE Jul Aug Sept Oct Nov Dec 4.0 WTP 18 Cumulative distribution of 2.6 WTP production is reasonably flat between 5 – 95 %ile. Distribution of Production as a Percent of Capacity (2.6 MGD) Plant Average Production (Percent) 100 97 % 95 90 85 80 79% 75 0 E&WE 10 20 30 40 50 60 Cumulative Percentile 70 80 90 100 19 Plant capacity use for true 2.6 WTP mostly between 87% - 90%. Probability (Percent) Distribution of Avg. Production as Percent of Capacity (2.6 MGD) 35 30 25 20 97% likelihood < 92% of capacity 15 10 5 0 Average Production (Percent of Capacity) E&WE 20 Capacity utilization of 2.6 MGD WTP ranges from 84% to 92% @ 5 – 95 percentile. Distribution of Plant Production (2.6 MGD Capacity) Percentile Average Production (% Capacity) MGD MG Year Lowest 1 79 83 2.0 2.1 746 783 5 10 25 84 85 87 2.2 2.2 2.2 798 808 821 50 75 90 88 2.3 90 91 2.3 2.4 836* 852 865 95 99 Highest 92 2.4 2.4 2.5 874 888 923 94 97 Percentile averages include the 20-year "run.“ E&WE 20% more than existing 2.1 MD WTP average production (695 MG) over 39 years: 141 MG. 21 Expected capacity utilization of 4.0 WTP is limited by reservoir storage. Plant Average Production (Percent) Distribution of Production as a Percent of Capacity (4.0 MGD) 100 95 92% 90 85 80 75 2.8 MGD “firm” 70 0 10 20 30 40 50 60 70 80 90 100 Cumulative Percentile E&WE SSR “firm” 2.6 mgd is not a point on the 4.0 production distribution; SSR reported costs for 2.84 mgd plant coincides with lowest point on the distribution. 22 4.0 WTP plant capacity use mostly between 79% - 82% -- limited by storage and flow variability. Distribution of Avg. Production as Percent of Capacity (4.0 MGD) Probability (Percent) 30 25 20 92% likelihood < than 84% of capacity. 15 10 5 0 Average Production (Percent of Capacity) E&WE 23 Capacity utilization of 4 MGD WTP ranges from 76% to 85% @ 5 – 95 percentile. Distribution of Plant Production Percentile Lowest 1 5 10 25 50 75 90 95 99 Highest Average Production (% Capacity) (4.0 MGD Capacity) MGD MG Year 77 79 2.8 3.0 3.0 3.1 3.2 1028 1085 1111** 1126 1150 81 3.2 83 84 3.3 3.4 3.4 3.5 3.7 1177* 1206 1229 1245 1272 1339 70 74 76 85 87 92 City Claims it is not building a 4.0 MGD WTP and will not significantly increase water withdrawals. Percentile averages include the 20-year "run." E&WE *69% more than existing 2.1 MD WTP average production (695 MG) over 39 years – 482 MG; **60% more than 695 MG. 24 Annual flow variability of Harpeth creates wider annual fluctuations for 4.0 MGD Plant. Annual Variability of 2.6 and 4.0 WTP between 5 and 95 percentile MGD 4.0 3.5 3.0 2.5 2.0 2.6 MGD E&WE 4.0 WTP 2.6 Mean 4.0 Mean Standard deviations: 4.0 = 0.5 mgd; 2.6 = 0.3 mgd. River flows too variable and storage too small to assure reliable annual supplies. 25 95th 95th 95th 95th 95th 95th 95th 75th 75th 75th 75th 75th 75th 75th 50th 50th 50th 50th 50th 50th 25th 25th 25th 25th 25th 25th 25th 5th 5th 5th 5th 5th 5th 5th 1.5 5 Results of Financial Analysis of Franklin Investment Decision: • E&WE Investment and Operating Costs 26 WTP investment amounts in the record: Three questions govern decision evaluation. Reported WTP Replacement Costs 2.6 MGD Plant Reservoir Contract Change Order, April 26, 2011 Less Federal Stimulus ? SSR Design Contract, November 2012 $3,946,763 ($1,000,000) $1,246,585 SSR Pump Station Contract, April 2013 PER Construction Cost Estimate, August 2014 $407,550 $11,666,900 Total $16,267,798 1 Can the savings from producing WTP Bin 3 supply and not buying HVUD Bin 4 supply recover this investment? 2 Are there reliability values of WTP that help recover this investment? E&WE 3 Would opportunity losses and externality costs change the financial evaluation? 27 Schedule of Investment Flows from cited documents. Capital Cost Schedule to Design and Build New Water Treatment Plant Reservoir less Federal Stimulus 2012 $2,946,763 2013 $221,935 2014 $413,581 PER Schedule of Construction 2015 $4,516,619 2016 $8,168,900 Total less Reservoir $13,321,035 Total Capital Cost $16,267,798 Annual Capital Charge 3%/20 ($895,383) Annual Capital Charge Reservoir 3%/20 ($198,069) Total Annual Capital Recovery ($1,093,452) 78% remains to be spent in 2015 & 2016. E&WE 28 SSR Reported Annual Operating Cost Table 7.2 SSR, Operating Cost of Firm 2.6 MGD Capacity Plant Item Yearly Production, Yearly Production, Averge Daily Production, Raw Water Pumping Membranes MG 1000 Gallons MGD Electrical 2.6 MGD Firm Capacity 1,035 1,035,000 2.84 NOT 2.6! $24,520 Electrical Chemical $13,250 $5,100 Electrical Chemical $16,420 $4,300 Electrical $10 UV-AOP Carbon Pressure Filters Current Chemicals All Chemicals $220,870 Electrical $67,770 $52,840 Finished Water Pumping Estimating Contingency (15%) Total $405,080 SSR, PER, August 2014, p. 51 E&WE What costs are missing? 29 Operating costs missing from SSR Analysis (1) Can’t run a plant w/o labor, building, vehicles, insurance and stuff. Water Plant Fixed Operating Expenses YE June 2013 Employee Costs $804,477 Insurance Costs $15,489 Building Costs $44,029 Vehicle Costs $25,518 Other $12,373 Consultant Services $19,983 Safety supplies $3,200 Equipment Repair $85,312 Subtotal Fixed Op Costs $1,010,381 Source: Jackson Thornton, 2014 Cost of Service Study, 12 months ending June 30, 2013 E&WE What else is missing from SSR Op Costs? 30 Operating costs missing from SSR Analysis (2) SSR Annualized Fixed Costs Omitted from Summary Carbon annualized Replacement Membrane annualized Replacement UV annualized bulb replacement Subtotal page 6 $124,965 $17,292 page 3 $3,309 page 4 $145,566 SSR, PER, August 2014 Any more missing costs? E&WE 31 Other WTP operating costs missing from SSR (3) Water Plant Variable Operating Expenses YE June 2013 Lab fees $8,173 Other operating supplies $7,451 Equip parts & supplies $35,692 Machinery $210 Total $51,526 Source: Jackson Thornton, 2014 Cost of Service Study, 12 months ending June 30, 2013 E&WE 32 Annual Op Cost WTP comprised of fixed elements and elements that vary with production. Total Annual Fixed Op Cost New Plant Fixed Annual Costs Existing WTP Fixed Annual Cost New Capacity $1,010,381 $445,466 Total Fixed Op Cost 2014 $1,455,847 Escalated to 2017 @ 3% $1,590,844 Variable op cost per 1000 G @ 2017 $0.265 per 1000 G Variable cost per 1000 G is mostly electricity cost from SSR with misc items from JT 2014 Cost of Service on prior slide. E&WE 33 6 Does Existing 2.1 MGD WTP Drinking Water Cost Less than HVUD? E&WE 34 COF Reported Operating Costs YE June 2013. Water Plant Fixed Operating Expenses YE June 2013 $804,477 $15,489 $44,029 $25,518 $12,373 $19,983 $3,200 $85,312 Employee Costs Insurance Costs Building Costs Vehicle Costs Other Consultant Services Safety supplies Equipment Repair Subtotal Fixed Op Costs $1,010,381 Water Plant Variable Operating Expenses Variable Op Costs Lab fees Electric Service Lab Chems & supplies Other operating supplies Equip parts & supplies Machinery Subtotal Total Operating Costs YE June 2013 COF Produced Water (1000 G) E&WE Cost per 1000 Gallons YE June 2013 $8,173 $112,633 $272,766 $7,451 $35,692 $210 $436,925 $1,447,306 468,976 $3.09 35 COF plant capital and op costs (2013) compared to HVUD cost. Existing Plant Capital YE June 2013 Plant Capital Stock Plant Capital Recovery @ 3%/20 Source: JT Cost of Water Study, 2014 Reservoir Investment net of $1,000,000 Capital Recovery @ 3%/20 Annual Capital Charge Cost per 1000 Gallons YE June 2013 $2,946,763 ($198,069) ($396,139) ($0.81) Operating Cost per 1000 Gallons ($3.09) Total Cost per 1000 Gallons ($3.90) HVUD Cost per 1000 Gallons 2013 Loss by operating plant 2013 E&WE YE June 2013 $2,946,779 ($198,070) $2.36 ($728,926) 36 City Administrator claims that WTP production is lower cost than HVUD purchase: True? COF Continuing Losses by Operating 2.1 WTP: 2011, 2013-2016 Cost per HVUD Cost 1000 Total Op Capital 1000 per 1000 Gallons Costs Recovery Total Costs Gallons Gallons $1.94 2011 621,693 $1,191,783 $209,879 $1,401,662 $2.25 $2.36 2013 472,254 $1,447,306 $396,139 $1,843,445 $3.90 $2.55 2014 660,049 $1,672,953 $396,139 $2,069,092 $3.13 $2.55 2015 645,218 $1,708,509 $396,139 $2,104,648 $3.26 $2.59 2016 645,218 $1,759,765 $396,139 $2,155,903 $3.34 source: JT, Cost of Operations, YE 2013; HVUD October 2014 Rate Forecast Assume: 2014 operating at ~86% capacity; 2015-2016 @ ~ 84% capacity. Loss ($195,578) ($728,926) ($385,967) ($459,342) ($485,917) NOT! E&WE 37 Optimistic Plant capacity use supports 2014-2016 2.1 WTP costs per 1000 G. COF 2.1 WTP Actual and Estimated Production (MG Year) 700 600 500 400 300 200 2008 E&WE 2009 2010 2011 2012 2013 2014 2015 2016 38 7 What Are The Savings/(Cost) For Build Or Buy? Do The Savings Recover The Investment Cost? E&WE 39 HVUD rates increased 2010 – 2014 to reflect costs of LT2, system expansion and redundancy. HVUD Rate History $2.60 $2.40 $2.20 $2.00 $1.80 $1.60 HVUD increased supply to 60 mgd. $1.40 2004 E&WE 2005 2006 2007 2008 2009 2010 Source: HVUD, Beth Finney, October 2014 2011 2012 2013 2014 2015 40 HVUD Guiding Rate Forecast HVUD Rate Forecast October 10, 2014 $3.60 $3.40 $3.20 $3.00 $2.80 $2.60 Rates increase @ 1.5% from 2015 $2.40 $2.20 $2.00 Source: Beth Finney, HVUD, October 10, 2014, HVUD E&WE COF incurs annual op cost with plant closure SSR 2014-reported as $458,250. (No details available.) 41 Why not use HVUD “worst” case rate forecast? Beth Finney Email to Bill Wade, October 9, 2014, 4;10 pm - re: worst case forecast. “That scenario is based on flat to negative sales -- no growth in volume. ... “I don’t think this scenario is likely – however I was asked to ‘model for the worst.’ . . .No sales [increase] after expanding this plant is the worst. Basically [the projection] is what will be needed should volume stay the same as we are today for the next 10 years.” As an economist, I judge her “worst” case to be unrealistic. Ms. Finney described the 1.5% forecast as “based on a conservative expectation of . . . Sales. Should sales exceed budget sooner, . . . , it is possible that these increases would be less or not as frequent.” The 1.5% rate forecast is a guiding scenario, not a best case. E&WE 42 Present Value 2014 of annual cost of operating WTP PV 2014 Annual Cost of WTP Selected Percentile Results Percentile 2.6 Capacity 4.0 Capacity Lowest $38,271,056 $39,337,598 1 5 10 25 50 75 90 95 99 Highest $38,402,067 $38,465,362 $38,497,035 $38,550,793 $38,610,666 $38,671,769 $38,723,960 $38,755,670 $38,811,137 $38,947,841 $39,561,018 $39,664,269 $39,719,291 $39,814,796 $39,922,014 $40,031,111 $40,125,865 $40,184,493 $40,285,986 $40,554,400 Percentile averages include the 20 year "run“ sequence. E&WE “Tight” distribution of PV costs is because most of the annual cost of capital recovery and operations is fixed. Only 8 – 12% of annual costs vary with water intake. 43 2.6 MGD WTP is higher cost than HVUD at all likelihoods of production levels. 2.6 WTP PV Losses compared to HVUD Purchases by %ile 0 (500,000) 5% 25% 50% 75% 95% (1,000,000) (1,500,000) (2,000,000) (2,500,000) (3,000,000) (3,500,000) (4,000,000) (4,500,000) (5,000,000) E&WE Buying 100% HVUD saves $2.2 - $4.5 Million – Present Value 2014. 44 4.0 WTP - PV lower cost than HVUD at production levels above 5 %ile. 4.0 WTP - PV Savings: WTP Production by %ile $9,000,000 $8,000,000 $7,000,000 $6,000,000 5 %ile $5,000,000 25 &ile 50 %ile $4,000,000 75 %ile $3,000,000 95 %ile $2,000,000 $1,000,000 $0 E&WE PV Annual cost of producing water in 4.0 MGD plant ~$5 - $9 million lower than PV HVUD purchase – Present value 2014. 45 2.6 WTP Illustrative cost comparison at 50 %ile. 2.6 WTP Cost v. HVUD purchased Cost ($ per 1000 G) at 50 %ile $6.50 $6.00 $5.50 $5.00 $4.50 $4.00 $3.50 $3.00 WTP 50 %ile E&WE HVUD Purchase During wet to normal years, costs are similar. (23-25,27,29-30,32,36) During lower flow to dry years, WTP costs are much higher. HVUD costs are more stable. 46 4.0 WTP Illustrative cost comparison at 50 %ile. 4.0 WTP Cost v. HVUD purchased Cost ($ per 1000 G) at 50 %ile $5.00 $4.50 $4.00 $3.50 $3.00 $2.50 $2.00 WTP 50 %ile E&WE HVUD Purchase 47 Investment in 2.6 MGD plant has no positive PV savings to recoup $16.3 Million. ($16,500,000) Note: %ile means NPV (loss) likely to be larger than y axis value. 2.6 WTP – NPV 2014: plant losses + Investment 5% 25% 50% 75% 95% ($17,000,000) ($17,500,000) ($18,000,000) ($18,500,000) ($19,000,000) ($19,500,000) ($20,000,000) ($20,500,000) Net Present Value 2014 E&WE 48 Investment in 4.0 WTP cannot not recover the $16.3 million Investment. 4.0 WTP - NPV 2014: Savings less Investment $0 5% Note: %ile means NPV (loss) likely to be larger than y axis value. 25% 50% 75% 95% ($2,000,000) ($4,000,000) ($6,000,000) ($8,000,000) ($10,000,000) No positive return on investment is possible. ($12,000,000) Net Present Value 2014 E&WE Even at unlikely 95%ile of 4.0 MGD plant, savings do not provide a positive return. 49 8 E&WE Does City’s Redundancy Claim Justify The Uneconomic Plant Investment? 50 “Redundancy” is not a magic rationale for the WTP expansion. Supply reliability is a long-established empirical concept in public utility planning – not an abstract idea. Supply reliability is a scientific and economic determination with well-established empirical methods. • Reliability is an empirical measure of a utility’s ability to deliver uninterrupted service. Calculated costs and benefits of supply reliability are the building blocks to determine whether a $16.3 million redundant investment is good use of taxpayer money. No evidence in the record supports benefits of redundancy. • No risk assessment of HVUD supply outage exists. • No cost of supply disruption exists to justify “fear.” • Claims by City Administrator include distribution failures E&WE unrelated to source of water. 51 Reliability planning has an established analytic method. “Redundancy” $16.3 M cost must be subjected to a defensible reliability analysis. 1 Develop costs of construction and operation for alternative water management plans. • Done: buy HVUD or build uneconomic plant. 2 Determine expected frequency, duration and severity of supply shortages matched to alternative plans. • Existing river flow and production analysis measures amount of summer-fall • 3 WTP shortfalls. No analysis of likelihood and severity of HVUD outage exists. Estimate the shortage-related costs for alternative water supply plans. • Build WTP entails HVUD as ~75 % supply at known costs. • Buy 100% HVUD entails unestimated risk of outage andunknown costs. 4 Determine options to mitigate the frequency and severity of shortages. • More finished water storage? Emphasis on conservation to reduce purchases? 5 Determine Externality and Opportunity costs that bear on supply options. • Balance values of all services provided by Harpeth River. E&WE 52 9 Incomplete Record Does Not Allow Responsible Decision E&WE 53 Instream flow values at risk reinforce WTP closure. Values of Harpeth myriad instream flow services reinforce economic decision to shut down WTP. • • Benefits of wastewater dilution ignored by the City of Franklin. Ecosystem benefits of improved water flows missing from the record. HVUD can replace 100% of water supplies from Harpeth River and Franklin WTP. • Lower cost and very high % reliability. (No measured likelihood of • outage.) Allows enhancement of River to capture opportunity values. Opportunity losses and externalities caused by withdrawals emphasize that financial cost analysis of HVUD v. WTP is insufficient basis for responsible management of taxpayers’ money and river resource values. E&WE 54 Most important policy questions have not been asked and answered. 1 What are the opportunities and externalities at stake for existing and expanded water withdrawals for drinking water? [Not in the Record.] 2 Are Harpeth flows for the drinking water plant or for wastewater dilution the more pressing economic use of the River? [Not Analyzed.] 3 Does changing “Face of Franklin” affect the decision to expand or close the existing water withdrawal plant? [Yes; Held values of Franklin residents differ today from people here even 25 years ago. Environmental values matter.] Record of decision incomplete without missing economic information. E&WE 55 Back Up: Corrected SSR Operating Cost – New Facility Yearly Production, MG Yearly Production, 1000 Gallons MGD Raw Water Pumping Electrical Carbon annualized Replacement Membranes Annualized Replacement Corrected Operating Costs "Firm" 2.6 MGD Plant 1,035 1,035,000 2.84 Variable electricity cost per 1000 Gallons; Page citations to unnumbered SSR Appendix $28,109 var 0.0272 per 1000 g page 3 $124,965 fixed page 6 $17,292 fixed page 3 Electrical Chemical UV AOP Annualized Bulb Replacement $21,174 var 0.0205 per 1000 g $5,100 fixed page 3 Electrical Chemical GAC Electrical All Chemicals Finished Water Pumping Electrical $23,392 var 0.0226 per 1000 g $14,100 fixed page 4 page 3 $3,309 fixed Page 4 Page 4 $10 fixed page 2 $222,586 fixed page 8 $92,395 0.0903 per 1000 g. Page 11 Other Costs from JT Cost of Service Lab fees Other operating supplies Equip parts & supplies Machinery Subtotal fixed fixed with 15% contingency Subtotal Variable production Variable with Contingency 15% Totals with 15% contingency source: SSR Estimated Operating Cost, 2014 $10,200 Var JT Cost of Service year ending June 2013, Operating Costs $7,451 Vari JT Cost of Service year ending June 2013, Operating Costs $35,692 Var JT Cost of Service year ending June 2013, Operating Costs $210 $387,362 $445,466 $218,623 $251,417 var JT Cost of Service year ending June 2013, Operating Costs Cost per 1000 g $0.243 $696,883 56 William W. Wade WILLIAM W. WADE Energy & Water Economics 1021 Riverview Drive Franklin TN 37064 615-628-8731 [email protected] Previous Positions: Senior Vice President, Foster Associates, Inc. Vice President/Partner, Spectrum Economics, Inc. Vice President/Partner, QED Research, Inc. Manager of Economics, Dames and Moore Consulting Engineers Corporate Economist/Financial Analyst, Standard Oil of California (Chevron) Key Qualifications: Water and Natural Resources Dr. Wade specializes in issues related to environmental resources and water policy -- working with executives, lawyers, engineers and scientists on multi-discipline regulation, litigation, and planning projects. He has 30 years experience managing and conducting financial and economic evaluations of policies and decisions bearing on natural resources and infrastructure. He has worked with many of the nation’s foremost water lawyers. Since 1986, he has conducted dozens of studies on various aspects of water supply, demand and valuation problems, including tradeoffs between protection of instream fisheries, habitat and recreation values versus consumptive use and residential reliability values. Dr. Wade has worked on significant water resource policy and litigation issues related to interstate and other conflicts among multiple uses of several watersheds: Sacramento-San Joaquin Delta, California; Colorado River, California; N-Aquifer, Arizona; ACT/ACF: GA-FL-AL; Tennessee Valley Harpeth River Duck River Buffalo River Piney River Republican River: Kansas v. Nebraska; Missouri River, Upper Midwest; Memphis Sands Aquifer: State of Mississippi v. City of Memphis; Florida surface and groundwater: Tampa Bay Water v. HDR, et al; California groundwater: City of San Diego v. Kinder Morgan; Virginia groundwater contamination: Royals v. Campbell County, VA; Northeast groundwater contamination: ongoing. 1 William W. Wade In related work, Dr. Wade has been qualified in state and federal courts as a financial economist valuing the effects of regulatory changes on land use projects. Beyond the indicated interstate and other cases indicated above, recent water resources work includes state of the art water demand elasticity estimation for a large California urban water agency and a Mid-South City, including the effect of water rates on outdoor water use, and valuations of specific supplies. In past litigation cases, he has estimated the values of groundwater and surface water supply disruptions. Dr. Wade has worked on various policy alternatives to assure reliable water supplies for the San Francisco Bay Area. He worked with a team of inside and outside TVA economists throughout much of 2002-2003 on TVA’s Reservoir Operations Study, conducting the economic analysis of alternative operations. From 1998 – 2001, he worked on issues related to the ACF/ACT Water Supply disagreement developing NED and RED benefit estimates for Atlanta water supply reliability and Lake Lanier recreation usage. From 1995 to 1999, he led a team of economists forecasting visitation and evaluating amenity mixes to implement the recreation master plan for Diamond Valley Reservoir, Riverside County, California. Dr. Wade’s Cost of Industrial Water Shortage remains a seminal report on the value of water within water intensive industries. In California, he presented testimony at SWRCB Bay-Delta Hearings on supply shortage costs and before CPUC and CA Legislative Committee on water rates to induce conservation by private water agencies, and presented information on drought impacts to California economy to Associated California Water Agencies Drought Hearings, and other forums. Other water agency clients include: San Francisco Bay Area Water Supply and Conservation Association, TVA, Santa Clara Valley Water District, California Urban Water Agencies, California Water Association, Metropolitan Water District of Southern CA., Los Angeles Department of Water and Power, Bay Area Water Supply & Conservation Agency, USBR, CDWR, Army Corps of Engineers, Department of the Interior, Nebraska DNR, State of Mississippi, Atlanta Regional Commission, Harpeth River Watershed Association and Duck River Development Agency. Recent Resource Economics Publications & Reports: Water Supply Planning and Reliability Valuation “Franklin’s Water Treatment Plant: Financial Analysis, Externalities, Responsible Management of River Resources and Taxpayers’ Money,” ongoing “Evaluation of groundwater damages due to presence of PFOA,” rebuttal for defense counsel, ongoing. Re-evaluation of IWRP for Franklin TN water supply plan, ongoing. Regulatory Takings, Texas Groundwater and the Edwards Aquifer Authority v. Day decision, presentation to Austin TX Eminent Domain Super Conference, February 11, 2013. “Temporary Takings, Tahoe Sierra and The Denominator Problem,” 43 Environmental Law Reporter 10189, February 2013. “Evaluation of San Diego groundwater contamination damages,” lawsuit-representing defendant, summary judgment for defendant dropping water loss damages, December 2012. “Evaluation of values for Tampa Bay Water reservoir storage for M&I use,” lawsuitrepresenting defendant: Plaintiff’s damages dropped based on my testimony and analysis, 2011. 2 William W. Wade “Review and Analysis of Duck River Water Supply Plan, 2010, 2011, 2012 & 2013.” “Reevaluation of Duck River watershed water demand forecast,” 2011 & 2013. “Sources of Regulatory Takings Economic Confusion Subsequent to Penn Central," 41 Environmental Law Reporter 10936, October 2011. “A Tale of Two Circuits: Penn Central’s Ad Hocery Yields Inconsistent Takings Decisions,” 42 The Urban Lawyer, summer 2010. “Federal Circuit’s Economic Failings Undo the Penn Central Test,” 40 Environmental Law Reporter 10914, September 2010. “Temporal Posture and Discount Rates for Groundwater Contamination Damages,” Environmental Law Reporter 10262, March 2010. “Evaluation of Demand Forecast for Duck River Water Supply Plan,” March 2010. “Valuation of Mississippi-owned groundwater used in MLGW service area,” lawsuit representing plaintiff: case removed from Federal Court sua sponte to U.S.S.C.- 2009. “Valuation of contaminated groundwater supplies for residential use,” (lawsuit representing plaintiff: decision for the plaintiff, award $9.0 million) 2009. “Regional Economic Impacts of large multi-use commercial, retail, residential development in Metro Nashville,” 2009. “Valuation of deficit irrigation due to water shortage,” Kansas v. Nebraska, 2008. “Regional Economic Impacts of Nissan Corporate Headquarters relocation to Metro Nashville,” 2008. “Valuation of Water Supplies in Eastern Watershed Conflicts and Planning,” Eastern Water Law and Policy Reporter, v. 3, no. 8, August/September 2008. “SB 3 - Environmental Flows Protection Requires Balancing with all Water Use Values at Stake,” Presentation to Texas Water Summit, San Antonio, December 3, 2007. “Evaluation of water supply alternatives contrasting M&I supply reliability and instream flow values at risk,” 2007. “Demand modeling and estimation in view of heterogeneous CA water agency residential user profiles,” 2007. “Time series demand modeling of City of Memphis residential and commercial end user classes,” June 2007. “Final critique of engineering economics and financial feasibility of City of Franklin proposed water treatment plant,” June 2007; revised 2008; under re-review 2010-2011. “Evaluation of anticipated economic impacts of 2007 drought-induced water shortages in the San Francisco Bay Area,” 2006-2007. “Evaluation of practicable alternatives to Harpeth River water supply,” presentation to TNAWRA Water Resource Symposium, April, 2007. “Economic criteria for regional water supply planning in Tennessee,” April, 2007. 40 3 William W. Wade “Water Supply Planning for City of Franklin: Comparison of Expanded Water Supply Plant v. Instream Flow Values for Wastewater Dilution and other Resource Values,” October 2006. “Evaluation of water supply alternatives to meet City of Franklin future demand,” August 2006. “Estimation of indoor and outdoor water demand, price elasticities and estimated future water use for alternative rate structures San Francisco Bay Area.” 2006. “ARAP and the economics of Piney River Water Supply Planning,” presentation to TNAWRA Water Resource Symposium, April, 2006. “Effect of increasing Hispanic population on California outdoor water recreation preferences and facility needs,” 2005. “Evaluation of Environmental Benefits of Hetch Hetchy Dam Removal,” 2005. “Achieving Reliability and Sustainability in Water Supply Planning,” California Law and Water Policy Reporter, October 2005. “Evaluation of Effect of SFPUC Water Supply Improvement Plan on San Francisco Bay Area Water Supply Reliability,” 2005. “Evaluation of Piney River Economic Alternatives to Meet Water District Demand,” 2005. Lake Lanier National Economic Development Update: Water Supply, Hydropower & Recreation Benefits, Final, 2004. "Evaluation of Missouri River Master Water Control Plan," 2004. "Effect of Water Supply Cutbacks of Midwest Irrigated Agriculture," 2002-2003. "Economic Analysis of TVA Alternative Operating Regimes to enhance power supply, navigation, recreation and flood control: Reservoir Re-Operations Study," 2002-2003. "Effect of Water Supply Allocations on Value of Republican River Watershed Agricultural Production and Recreation," Kansas v. Nebraska, 2002 & revised in 2003. "Alternative Water Supply Sources and Recreation values," Kansas v. Nebraska, 2002. "Comparison of Irrigated Agricultural Economics Research Dealing with Crop Water Use," Kansas v. Nebraska, January 2002. "IRP Approach To Water Supply Alternatives for Duck River Watershed," presentation to Tennessee AWRA Conference, April 2002. "Lake Lanier National Economic Development Update: Evaluation of Water Supply, Hydropower and Recreation Benefits," draft report, November 2001. "Economic Value of Municipal and Industrial Water Supply Reliability for Metropolitan Atlanta," draft, May 2001. "Evaluation of Water Supply Alternatives for Duck River Watershed," 2001. “Reliability Values for Least Cost Planning,” 2001. "The Value of Reliable Urban Water Supply," 2001. 4 William W. Wade “Recreation Values at Risk to Water Delivery Shortfalls,” 2001. "TN Regulations Balance the Beneficial Uses of Water," 2001. "Economic Benefits of Recreational Boating on the Buffalo River," 2001. “Least Cost Water Supply Reliability Planning,” Tennessee Water Resources Symposium, April 2001. “Predicted Recreation Visitation to Sacramento-San Joaquin Delta for Boating and Fishing,” 2001. “Water Supply Planning in the Duck River Watershed After the Fleecing,” TN Water Resources Symposium, April 2000. “Economic Shortcomings of ACF EIS Water Supply, Recreation & Regional Impacts Appendices,” Atlanta Regional Commission, 1999. “Forecasting & Evaluating Reservoir Recreation Financial Feasibility and Regional Economic effects,” 1994 - 1999. “Economic Considerations of Regulatory Takings,” Presentation, Restructuring in California: The Morning After, Law Seminars International Conference, Sacramento, CA, September 1998. “California Water Supplies: Problem Solving through the 20th Century,” Presentation, Southeast Water Resources: Management and Supply Conference, Chattanooga, Tennessee, August 1998. “Planning for Revenue Positive Freshwater-Related Recreation Projects,” Presentation, American Water Resources Association Annual Conference, Mobile, AL, 1998. “Problems with Bay-Delta Recreation Visitation Estimates—Revisited,” 1998. “Estimating Potential Demand for Freshwater Recreation Activities, Southern California: 1997-2020,” 1998. “Freshwater Recreation Demand Forecasting in Southern California,” 1998. "Evaluation of Private/Public Alternatives for Municipal Reservoir Recreation Planning,” 1997. "Financial Feasibility of Bass Fishery Enhancement in Southern California,” 1997. "Economic Impacts, “The Bennett Decision and Investment-Backed Expectations,” California Land Use Law Reporter, July 1997. “Evaluation of Recreation Revenue Shortfalls at Lake Skinner,” 1996. “Status of Efforts to Resolve California's Water Problems,” 1995. “Economic Considerations of Regulatory Takings Reform: Judicial Precedent and Administrative Law v. Legislative Intent,” BNA Environmental Reporter, August 4, 1995. “The Role of Economics in Regulatory Takings Cases,” with Robert Trout, Litigation Economics Digest, 1, 1, fall 1995. “California's Dual Water Crises: Add Fish and Feds and Shake Thoroughly,” California Water Law and Policy Reporter, March 1994. 5 William W. Wade “Economic Costs of EPA Bay Delta Water Quality Standards,” Presentation to California Water Resource Agencies, March 1994. "California Water Supplies in the 1990's: Add Fish and Feds and Shake Thoroughly—or, The Increasing Unreliability of Consumer Supplies in the Environmental Age,” Presentation to Conference of California Public Utility Counsel, November 1993. “Water Supply Planning Simulation and Estimated Shortage Costs Related to Mono Lake Diversion Alternatives,” August 1993. Testimony before SWRCB November, 1993. “The Economic Effects of Implementing the Central Valley Project Improvement Act,” California Water Reporter, February, 1993. “Water Supply Reliability Epochs: Revenue Instability for Retail Water Utilities,” Testimony to CPUC, November 1992. “Drought Impacts on California Green Industries,” January, 1992; Submitted to SWRCB as State Water Contractors Exhibit 20, June, 1992. Presentation to California Legislature, Assembly Utilities and Commerce Committee, “Investor Owned Water Utilities: Rates, Reliability, Regulation,” February 1992. “Financial Impacts of Decreasing Wholesale Water Supply Reliability on Class A Water Utilities,” 1992. Cost of Industrial Water Shortages, November, 1991. “The Cost of Water Shortages: Case Study of Santa Barbara,” 1991. “Planning for Reliability for California's Urban Water Agencies,” 1991. “Impacts of Drought on California Economy, Testimony to ACWA Drought Conference,” October, 1990. “Financial Partnerships to Assure Conservation's Role in California Water Supply Resource Planning,” Testimony to CPUC, June 1989. "Supply Reliability Planning for Water Utilities," 1989. "Economic Value of Reliable Water Supplies for Industrial Water Users," SWC Exhibit 57, 1987. Environmental Values and Trade-offs “Economic Impacts of Keystone XL Pipeline based on REMI Model Analysis,” March, 2012. “Effects of BP oil spill on LA Parish resource values and government revenues,” 2011. “Effects of BP oil spill on LA Parish natural resources values,” 2011. “Unbalanced Housing Development Pattern Part of the Drag on Maury County Economy,” Maury County Comprehensive Planning Process, July 24, 2008. “Smart Growth aspects of large multi-use commercial and residential development,” 2009. “Economic and fiscal effects of large multi-use commercial and residential development in Nashville, 2008-2009. 6 William W. Wade “Confusion about “Change in Value” and “Return on Equity”Approaches To Penn Central Test in Temporary Takings,” 38 Environmental Law Reporter 10486, July 2008. “Average Reciprocity of Advantage: ‘Magic Words’ or Economic Reality: Lessons from Palazzolo," 39 The Urban Lawyer 319, spring, 2007. “Evaluation of Environmental Benefits of Hetch Hetchy Dam Removal,” 2006. “Advances in Measurement of Penn Central’s Economic Prongs and Estimation of Economic Damages in Federal Claims and Circuit Courts,” 38 The Urban Lawyer, 337 spring, 2006. “Policy Evaluation of Natural Resource Injuries using Habitat Equivalency Analysis,” Ecological Economics, 2005 w/Brian Roach. “Advances in Measurement of Penn Central’s Economic Prongs and Estimation of Damages in Federal Claims and Circuit Courts,” Paper for fall ALI-ABA Takings Conference, 2005. "Guidelines for Conducting the Penn Central Test," Conf. Litigation, 2004. "Policy Evaluation of Natural Resource Injuries Using Habitat Equivalency Analysis," presented (by co-author Brian Roach) at the U.S. Society for Ecological Economics Conference, Saratoga Springs, NY, May, 2003. "Middle Tennessee Land Use Decisions Ignore Tourism Values at Stake to Poor Planning," May, 2002. "Economic Backbone of the Penn Central test post Florida Rock V, K & K and Palazzolo," 32 ELR 11,221, October, 2002. "Franklin fails to see tourism dollars in battlefield site," 2002. "Spring Hill Land Use Planning Needs a Vision," 2001. "Lake Lanier Recreation NED and RED Benefit Values: A Random Utility Model Approach," 2001. “Estimating Environmental Externalities related to MMS 5-Year Lease Program,” 2001. “Penn Central Test Criteria and Damage Estimates in Takings Case,” confidential litigation, 2000. "Forecast of Freshwater Recreation Demand for Southern California Reservoirs," 1999. “Review of Issues Related to Divestiture of Dams and Related Hydroelectric Facilities,” 1999. “Penn Central’s Economic Failings Confounded Takings Jurisprudence,” The Urban Lawyer, spring 1999. “Environmental Damages Related to Gulf of Mexico Coastal Sediment Contamination,” confidential litigation, 1995. “Role of Economics in Regulatory Takings Cases,” Litigation Economics Digest, 1, 1, fall, 1995. “Economic Considerations of Regulatory Takings Reform: Judicial Precedent and Administrative Law v. Legislative Intent,” BNA, Environmental Reporter, August 4, 1995. “The Role of the Economist in a Regulatory Taking Claim,” California Land Use Law and Policy Reporter, March, 1995. 7 William W. Wade “Environmental Damages Related to Groundwater Contamination,” confidential litigation, 1994. “Colorado River Critical Habitat Studies: Environmental Benefits v. Consumptive Losses,” 1994. "Tribal Lifestyles, Traditional Values and Water Requirements for the Hopi and Navajo in the Arizona High Desert," 1993. “Approach to Incorporate Existence and Option Values for Southwestern Native American Water Rights,” 1992 - 1994. “Critique of Mono Lake Contingent Valuation Survey,” December 1993. Testified at SWRCB Dec. 1993. “Natural Resource Damage Assessment: A Path Through the Pitfalls of Evolving Regulations,” Contemporary Studies in Financial Analysis, Vol. 74, ed. Thronton, R. and Aronson, R.J., Jai Press, New York, New York, 1993. “Recreation Forecasts and Benefit Estimates for California Reservoirs: Recalibrating the California Travel Cost Travel,” 1991. “Potential Freshwater Recreation Demand Forecast by California County - 1990 to 2035,” 1990. “Recreation Benefits for California Reservoirs: A Multisite Facilities-Augmented Gravity Travel Cost Models,” April, 1989. “Estimating Instream Flow Recreation Benefits on the American and Sacramento Rivers,” 1988. “Trends in Fresh Water Recreation Demand in Southern California,” 1988. “Critique of Contingent Valuation Studies Related to Bay Delta,” State Water Contractors Exhibit 90, 1987. “Economic Evaluation of the Recreation Resources of California's State Water Project and the Sacramento-San Joaquin Delta,” State Water Contractors Exhibits 64 and 66, June and September 1987. “Economic Values of Water Shortages to MWD Service Area (Los Angeles) based on IMPLAN regional economic impact model,” 1987. (Project Manager) “Methods to Value Benefits to Natural Resources Associated with Bay-Delta Water Diversions,” 1987. Education: Ph.D., Resource and Applied Economics, University of Minnesota M.S., Agricultural Economics, University of Minnesota B.S., English/Journalism, Spring Hill College Professional Activities: TN Water Supply Planning Panel; Former Treasurer, TN AWRA; Former Member of Economic Advisory Council, California Chamber of Commerce; Past President of San Francisco Chapter of 8 William W. Wade National Association of Business Economists; American Economics Association; American Agricultural Economics Association; Association of Environmental and Resource Economics. Kiwanis Club of Columbia, TN. Honors: Award for Professional Excellence for Quality of Published Research, 1979; (with others) American Agricultural Economics Association. 9 MEMORANDUM TO: CC: FROM: DATE: JOB NO.: RE: Dorie Bolze, HRWA John Michael Corn, P.E. (TN) November 3, 2014 142331 Water Withdrawal Analysis for the Harpeth River AquAeTer was asked to analyze the Harpeth River flow at the United States Geological Survey (USGS) gage at Franklin, gage number 03432350. The available data from January 1, 1975 through September 25, 2014 were downloaded. This analysis utilizes the available gage data to determine the amount of water that could be produced for potable water use using various Water Treatment Plant sizes. The historic period of record is used to predict what may occur in the future. BACKGROUND The City of Franklin operates a drinking water plant (WTP) in Franklin, Tennessee. The source of water is the Harpeth River. A pumping station is present near the WTP, upstream from the USGS gage. No records were available for historic withdrawal rates prior to 2007. No attempt was made to estimate the amount of water removed to determine the amount of water coming to the WTP. The current WTP is operating under the following withdrawal conditions. At no time can the Plant withdraw water when the flow at the gage is less than or equal to 10 cubic feet per second (cfs), nor can it cause the flow to dip below 10 cfs. At flows greater than 10 cfs, the WTP can withdraw up to 20% of the flow. However, the analyses for this exercise utilize this water withdrawal limitation, but with modifying the allowable withdrawal from 20% to 15% in order to use the same assumption used by Smith Seckman Reid, Inc. (SSR) in their Preliminary Engineering Report (PER) on the Water Treatment Facility Expansion for the City of Franklin (August, 2014). The WTP utilizes a reservoir that was recently rehabilitated to store raw water prior to producing potable water in the WTP. The analyses presented here use the maximum reported volume of 113 million gallons. The minimum reported volume from which water can be withdrawn was reported as 34.25 million gallons, according to the SSR PER and the spreadsheets provided that back up the work in the PER. Therefore, the operating volume utilized for this analysis was 78.75 million gallons. This analysis also incorporated leakage at 0.25 MGD as reported in the documents in the City’s 2012 ARAP permit application. ANALYSES For the period of record analyzed, the USGS gage had flow data for the entire period or record. A total of 14,513 days were included. The USGS reports flow in cfs. An additional column was added to convert the flow to million gallons per day (mgd), which are the units that the WTP reports. The following equation relates these two units: 𝐹𝐹𝐹𝐹 (𝑐𝑐𝑐) = 𝐹𝐹𝐹𝐹 (𝑚𝑚𝑚) 1.547 1 A column was added then to calculate the water available for withdrawal. The flow at the gage was analyzed. If the flow was less than 10 cfs, the available water for withdrawal was 0 cfs. If the flow was greater than 10 cfs, but less than 10/0.85 cfs, then water could be withdrawn up to the point where 10 cfs was left in the river. If the flow was greater than 10/0.85 cfs, then 15% of the water could be withdrawn. The following equations show the formulas used: 𝐼𝐼 𝐹𝐹𝐹𝐹 (𝑐𝑐𝑐) ≤ 10 𝑐𝑐𝑐, 0 𝑐𝑐𝑐 𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑓𝑓𝑓 𝑤𝑤𝑤ℎ𝑑𝑑𝑑𝑑𝑑𝑑 2 𝐼𝐼 10 𝑐𝑐𝑐 < 𝐹𝐹𝐹𝐹 (𝑐𝑐𝑐) 10 𝑐𝑐𝑐 ≤ , 𝐹𝐹𝐹𝐹 (𝑐𝑐𝑐) − 10 𝑐𝑐𝑐 𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑓𝑓𝑓 𝑤𝑤𝑤ℎ𝑑𝑑𝑑𝑑𝑑𝑑 0.85 𝐼𝐼 𝐹𝐹𝐹𝐹 (𝑐𝑐𝑐) > 10 𝑐𝑐𝑐 , 𝐹𝐹𝐹𝐹 (𝑐𝑐𝑐) ∗ 0.15 𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑓𝑓𝑓 𝑤𝑤𝑤ℎ𝑑𝑑𝑑𝑑𝑑𝑑 0.85 The water withdrawn from the River is placed into the WTP reservoir. The Harpeth River can have prolonged periods of flows less than 10 cfs. A running count of days in which the Harpeth River was at or below 10 cfs was tabulated. For the period of record, the longest consecutive number of days that were at or below 10 cfs was 115 days. The following chart shows the frequency of extended periods of time in which the Harpeth was at or below 10 cfs. The number of times a low-flow period has extended over multiple weeks is presented in Figure 1. For instance, for the 39-year period analyzed, there have been 106 times when the WTP would not have been able to withdraw water for at least one full week under the current restrictions. There have been two times when the low flow extended for more than 11 weeks. 2 In order for the WTP to continue to operate during low flow periods, a reservoir or a secondary source of water is necessary. The WTP has a reservoir with an operating volume of 78.75 million gallons. Three different sized plants were evaluated. For each, the working volume was used. For the purposes of this analysis, the 34.25 million gallons of minimum operating volume was treated as a minimum. When this volume was reached, the WTP was not able to operate until additional water was added to the reservoir. If any water was present above 34.25 million gallons, the WTP was assumed to operate until the reservoir reached the minimum pool. For these analyses, raw water losses from the reservoir were assumed to be 0.25 mgd due to leakage. Evaporative losses were not accounted for in this analysis, but could be significant. Figure 1. Number of Times Extended Low Flow Periods Have Occurred Number of Occurrences 120 106 100 80 66 60 43 40 31 20 20 12 6 4 3 2 2 1 1 1 1 1 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Time (weeks) 2.1 MGD WTP A case was run with a WTP that produced a maximum of 2.1 mgd. This analysis does not include the losses due to leakage and normal operations (e.g., backwashing filters). So the WTP would not necessarily deliver 2.1 mgd to the distribution system. For this case, a water withdrawal pump with a capacity of 7 mgd was used. This is the current design capacity of the existing raw water pump according to the PER. When water was available from the Harpeth River, the pump was assumed to withdraw up to 7 mgd. The calculation did not allow the reservoir to exceed 113 million gallons. For instance, if the reservoir was at 113 million gallons and the WTP produced 2.1 mgd, then the pump replaced the 2.1 mgd, as long as more than 2.1 mgd was available from the Harpeth River. 3 For this analysis, there were 1,608 days in which water could not be produced due to the lack of a reliable source of water. This is extended to 1,755 days of not being able to produce 2.1 mgd. The longest period of time in which water could not be made was 98 days. The longest period of time in which 2.1 mgd could not be produced was 123 days. It is likely that this period would be extended if the evaporative losses from the reservoir were calculated. 2.6 and 4.0 MGD WTP Two cases were run, one with a maximum capacity of 2.6 mgd and one with a maximum capacity of 4.0 mgd. For both cases, the water withdrawal pump was assumed to have a capacity of 8 mgd, which was the pump flow rate utilized in the Preliminary Engineering Report made by Smith Seckman Reid for the City of Franklin. As with the 2.1 mgd case, the analysis does not attempt to determine the actual water delivered to the distribution system, which is expected to be some percentage of the total produced water. As with the case with the 7 mgd withdrawal pump, the analysis assumes the 8 mgd pump cannot add more water than 113 million gallons to the reservoir. For these analyses the periods when no water could be produced, as well as the periods when the maximum capacity could not be made are summarized in Table 1. Also included are the maximum period of time when water could not be produced and the maximum period of time when the WTP would not meet its capacity. Impoundment Size The impoundment has an operating volume of 78.75 million gallons. The size of the WTP that would not be down due to lack of water based on the historical flows can be determined. For this analysis, the leakage rate from the reservoir was assumed to be 0.25 mgd and the water withdrawal pump was assumed to be 7 mgd. The WTP can be expected to produce 0.42 mgd reliably based on the historical water supply and the current impoundment basin size. In other words, if the plant produced only 0.42 mgd, we would expect that it could run at capacity year round, based on the historical flow record and the current impoundment size. Water Harvesting An analysis was made to determine what size impoundment basin would be required to operate each of the water treatment plants at their capacities without shutting down. This analysis assumed: 1) no withdrawals to less than 10 cfs; 2) a maximum withdrawal of 15% of the flow; 3) a daily leakage rate of 0.25 mgd; and, 4) a minimum operating level of 34.25 million gallons. Evaporative losses were not accounted for in this analysis. Based on the historical flow record and the analyses completed and described previously, the basin sizes are determined by the number of consecutive days in which water could not be produced. This analysis was 4 TABLE 1. SUMMARY OF ANALYSES Period: January 1, 1975 – September 25, 2014 (14,513 days) CONDITION PLANT SIZE 2.1 2.6 4.0 MGD MGD MGD Number of Days When No Water Could Be Withdrawn Percentage of Time When No Water Could Be Withdrawn Maximum Number of Consecutive Days No Water Withdrawn 2,860 20% 2,860 20% 2,860 20% 115 115 115 Number of Days When No Water Could Be Produced Percentage of Time When No Water Could Be Produced Maximum Consecutive Number of Days with No Water Produced 1,608 11% 1,933 13% 2,690 19% 98 111 127 Number of Days When Plant Not at Capacity (includes times when water is not produced) Percentage of Time When Plant Not at Capacity Maximum Consecutive Number of Days Not At Capacity 1,755 12% 123 2,184 15% 130 3,423 24% 169 Total Number of Days in Record Analyzed 14,513 14,513 14,513 completed to determine the raw water reservoir size that would be required in order for a WTP to operate at design capacity for each plant size based on the historic flow record. The historic flow record can be used as a basis for design to account for the variability of the water source, but it does not guarantee that a longer period without withdrawals would not occur in the future. 5 TABLE 2. SUMMARY OF RESERVOIR VOLUMES NEEDED WTP SIZE TOTAL VOLUME REQUIRED (million gallons) 2.1 mgd 2.6 mgd 4.0 mgd 405 510 1,065 If you should have questions or comments concerning our assessment, please call us at (615) 373-8532 or by FAX at (615) 373-8512 or by e-mail at [email protected]. 6
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