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2 008 YIELD STUDY DISCUSSION

Comments on Yield Study Performed by CTI for SUD
Lyle Brecht, Commissioner 17 September 2008

Disclaimer: The views expressed in this report are purely those of the author and may not in any circumstances be regarded as stating an official position of the organizations involved.

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2 008 YIELD STUDY DISCUSSION
Comments on Yield Study Performed by CTI for SUD
Lyle Brecht, Commissioner 17 September 2008
PURPOSES OF STUDY: The original purposes of the study were twofold: (1) Given that a developer was asking in March 2007 for potentially ~1,200 Equivalent Residential Units (ERUs) connections at final build-out, did the district have adequate supply to accommodate this development; and (2) given that the last capacity calculations had been done in 1993 and that the processes associated with global warming had altered climate assumptions since then, the board believed it prudent to update yield calculations. Another purpose was added later on in the study due to the district experiencing a D4 (Extreme) Drought from June 2007 through January 2008 where, by December 31, 2007, the district’s two primary reservoirs were within ~100-days of being fully depleted at an average day demand (ADD) during 2007 of 321,819 gallons per day (gpd). This secondary purpose was to calibrate the model used to calculate yields to resemble real-life experience of the district during the 2007 drought. DEFINITIONS: What are being calculated are yields that provide a guide to making decisions such as how many additional ERUs can be connected to the district’s water supply and how soon should the district plan augmenting its present supply capacity. That is, how much water can be withdrawn from the district’s primary and emergency supply year-in-and-year-out, under all anticipated precipitation regimes and not worry about running out of water for its customers? The common term to describe the answer to this simple question is safe yield. In its simplest incarnation, safe yield refers to the highest level of demand that a system can sustain in the worst drought on record (with no supply remaining). The 1993 W.A. Wauford study calls this calculation the Maximum Drought Yield; the CTI study calls this calculation the Maximum Yield. The CTI study also introduces calculations, under different assumptions of precipitation and supply flow, of the highest level of demand that a system can sustain using inflow from the system’s watersheds, but not depleting the system reservoirs. CTI calls these watershed flows – safe yield under

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conditions of drought and average precipitation and calculates a maximum yield under conditions of average precipitation.1 YIELD STUDY LEARNINGS 1) The ongoing yield of the district’s supply reservoirs, especially in times of supply stress (e.g. drought) is almost entirely dependent on the protective measures of the sub-watersheds that feed these supply reservoirs assuming a given precipitation.2 2) Land-use changes to either of the O’Donnell and/or the Jackson/Dimmick sub-watersheds will affect the whole supply system. It may be difficult or impossible to segregate land-use changes in one sub-watershed from another or land-use changes around one reservoir from affecting total system yield.3 3) Any activities that generate pollution in the watersheds will, most-likely, end up in the water supply reservoirs. Land-use and watershed management practices that keep pollutants out of the watershed (e.g. petroleum products and petrochemicals such as chlorinated hydrocarbons, etc.) are

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CTI’s use of the term safe yield assumes the district pumps only the amount of inflow to the watershed that is replenished naturally through precipitation. That natural replenishment is known as recharge. Under natural conditions, recharge, or inflow from the watershed, eventually results in an equal amount of water that is discharged into a reservoir, stream, spring, or seep. If one pumps more than the recharge, you will dry up streams, marshes, and springs, as well as the supply reservoirs. Pumping equal to or close to safe yield could cause dramatic loss of aquatic life, damage surrounding ecosystems, and result in significant loss of groundwater reserves. Thus, safe yield may not really be “safe” but should be viewed as an estimated limit (stated as one numerical value, but representing a probabilistically determined range of values), beyond which the system is most-likely moving toward collapse, away from sustainability. The sustainable yield of a system is typically considerably less than recharge if adequate amounts of water are to be available to sustain both the quantity and quality of streams, springs, wetlands, and ground-water-dependent ecosystems.
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These watersheds, the area of land that drains into a common water source, are natural assets that deliver a stream of goods and services to the community. These services include the supply and purification of fresh water, the provision of habitat that safeguards biological diversity, the sequestering of carbon that helps mitigate climatic change, and the support of recreation and biological research. Land-use changes and inappropriate land management practices diminish the ability of a watershed to perform its ecological work. The progressive loss of these services risks harm to human health through lowered drinking water quality, the introduction of waterborne human pathogens and organic contaminants, reduced dry-season flows, and higher water costs. See Sandra L. Postel and Barton H. Thompson, Jr., “Watershed protection: Capturing the benefits of nature’s water supply services,” Natural Resources Forum 29 (2005) 98-108.
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Since each of these reservoirs is dependent on the hydrologic cycle (i.e. rainfall) for its supply, the state of the watershed is the primary determinant of the quantity and quality of the water draining into these reservoirs. It turns out that, the less disturbance of the natural cover of the watershed, the more quantity of higher quality water is deposited in the water supply. This accomplishes three purposes: retaining natural vegetation typically increases and stabilizes the amount of water available from these water sources through times of varying precipitation, it reduces the potential adverse health impacts on life forms using the water supply, and it reduces the treatment costs if these water supplies are used for human consumption.

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likely less expensive than removing these pollutants once they have entered the water supply (if that is even feasible). 4 4) The ideas of and calculated values of safe yield and maximum drought yield have built-in limitations that must be taken into account: a. The calculations of safe yield presume stationarity. Yet, we now live in a world governed by non-stationarity due to abrupt climate change that suggests that past weather frequency, severity, and length of drought may not necessarily be a good or reasonable predictor of future drought frequency, severity, and length. b. Safe yield calculations assume that supply stress events occur with the probability predicted by a normal distribution curve. For example, a 100-year drought should occur with a frequency of 1% each year, or once every 100-years. However, drought frequency, severity, and length are better explained by a power law distribution than a normal distribution. In practice, what that means is that extreme drought is likely to occur more frequently than predicted under a normal distribution of drought events (e.g. once every 520 years rather than once every 100 years). Also, operationally speaking, when one enters a drought event, not until the drought is over will the Manager know whether the drought was extreme. Safe yield does not adequately take into account either set of dynamics or provide the operational intelligence to adequately make decisions for managing remaining supply during drought. c. Safe yield modeling does not adequately account for: (i) timing and sequencing of pumping scenarios among the three supply reservoirs; and (ii) assumes that all runoff from annual precipitation less evaporation is available for pumping from the reservoirs. These two issues may potentially provide either an over or underestimate of actual yield during a real drought that is significantly different from theoretical yields obtained from a linear model used to calculate safe yield. This is because, ultimately, actual, real-world yield is determined by the nonlinear dynamics of the inflow to and outflow from the threereservoir system. 5) In practice, pumping at or near the safe yield could cause dramatic loss of aquatic life, damage surrounding ecosystems, and result in significant loss of groundwater reserves.

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Public Water System (PWS) responsibilities for source water protection are described in Public Water System Regulation 1200-5-1-.34 and consist primarily of preparing and conducting an annual inventory of the contaminant sources in its recharge area. PWSs using surface water generally do not own all the property surrounding their supply and typically cannot control discharges by other entities. Under the provisions of 1200-5-1-.34(5) the state can require a pollution prevention plan from the discharger and require best management practices be employed to prevent contamination of water supplies. The Tennessee Safe Drinking Water Act at T.C.A. 68-221-711(5) makes the discharge of a contaminant near an intake that endangers health a prohibited act. With enforcement actions by TDEC and penalties that may be assessed, the damage does not have to have occurred – a reasonable threat should be enough. The PWS can also go to the local District Attorney and push him to enforce the provisions of the Act.

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DISCUSSION: There is no absolute, analytically determined, right number to use to manage the district’s supply and make capacity decisions. The yield models produce better or worse estimates of supply capacity under widely varying conditions. Better modeling will produce better results, assuming good data is put into the models. The models are getting better over time. Since 1973, each calculation of safe yield has produced better estimates of the capacity of the district’s system. However, the hard and important decision is how much risk does the board desire the district and its customers should be asked to bear? Safe yield calculations only point at different levels of risk. In reality, decisions regarding capacity and supply additions are risk management decisions. The board must choose the level of risk it wants to live with. Safe yield should be used only as a guide to arrive at the desired level of risk, not the sole determinant of policy regarding capacity and supply augmentation decisions. STUDY IMPLICATIONS & RECOMMENDATIONS: 1) For planning purposes, the board should consider using ~500,000 gpd average day demand as the maximum allowable average demand for the district. [Considering the results from the Phase II Calibration Raw Water Study, CTI believes that ~550,000 is a reasonable planning safe yield number to use.] This assumes that there are no alterations of the present O’Donnell and Jackson/ Dimmick sub-watersheds, such as deforestation from development and that all of Dimmick is available for the use as supply in dire emergencies. This also assumes a pumping strategy of during the year where water is pumped from Jackson to O’Donnell until both reservoirs are dry, then the top two feet of Dimmick is pumped for withdrawal at O’Donnell until the top two feet are exhausted. In practice what this means is that, if present average demand is ~300,000 gpd, the district can allocate another ~200,000 gpd, or connect an additional ~750 ERUs (@ 266 gpd/ERU average day demand for new construction/385 gpd/ERU peak consumption). If the district has 110 ERUs already committed or in-process, then an incremental 640 new ERUs capacity remains with existing primary supply. This implies that the district should have another minimum 100,000 gpd average day demand safe yield of additional primary supply available to it sometime before another ~500 ERUs are added to the SUD system. 2) Using an average two percent growth rate in demand, a 500,000 gpd average day safe planning yield is enough for the existing primary supply of O’Donnell and Jackson and emergency supply of Dimmick to provide adequate capacity for ~30 years. However, full build-out of the Cooley’s

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Rift development could potentially require the district to add additional supply within a five to eight years period, assuming the district chooses to serve this new development.5 3) One way that some utilities in the western United States handle large developments that ask for many hundreds or thousands of new connections for final build-out is to require these developments to bring their own water supply that is deeded over to the water utility (much as some utilities require large developments to bring their own package wastewater treatment plant). This reduces risk in that the utility does not have to buy expensive new supply specifically for the development, and a source of supply is assured for the development. Under the district’s present developer’s agreement, the district is allowed to make special requirements of large developers: This Rule shall serve as a guideline for the consideration of the request for water and sewer service for a large development, but the District may modify or add provisions of this Rule in making a commitment for water and sewer service for a large development (1. Application of Rule). 4) The proposed limit of 500,000 gpd average demand for planning purposes assumes the availability of Lake Dimmick for emergency supply. This enables the district to allow demand to grow approximately equal to the recharge rates to the O’Donnell and Jackson reservoirs during average

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AVERAGE DAY DEMAND GROWTH PROJECTIONS TODAY (2007) 500000

YEAR AVAILABLE YIELD (gpd) [Approximate] ADD (gpd) @ 2% GROWTH

10 YEARS 495000

20 YEARS 490050

30 YEARS 485150

40 YEARS 480298

50 YEARS 475495

301045

366972

453551

545301

664719

821544

SURPLUS OR (DEFICIT) (gpd)

198955

128028

36499

-60152

-184421

-346049

ADD (gpd) @ 1.7% GROWTH: CONSERVATION

356321

421746

499183

590840

699325

SURPLUS OR (DEFICIT) (gpd)

138679

68304

-14034

-110542

-223830

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precipitation and still have adequate supply during periods of drought. Without access to Dimmick for emergency supply, the district would be at or near its limit for new connections to its system with its present demand. However, presently Lake Dimmick is available for emergency supply only under a ten-year agreement with the University of the South. Therefore, the board may wish to consider entering into a longer-term agreement for emergency access to Dimmick or another arrangement that would assure this source of supply on a long-term basis if the district plans to allow demand to approach a safe yield of 500,000 gpd average demand. 5) A potentially least-cost means to achieve an incremental 100,000 gpd of safe yield and extend existing supply may be by programmatically targeting a reduction in average gpd/ERU from 266 gpd/ERU for new construction to 144 gpd/ERU, and from 188/ERU for existing connections to 144gpd/ERU for existing connections through demand management, conservation rates, and mandates and incentives for structural end-use conservation (as opposed to situational conservation that occurs during drought emergencies). This target of 144 gpd/ERU has been achieved by water utilities in the western United States who have well-managed, active ongoing programs budgeting as much as $23.00/year/ERU to achieve and maintain this objective. Typically, utilities that have succeeded with this approach have set 10-year timetables as a minimum period to achieve these conservation objectives. 6) A proven, least-cost means to maintain existing safe yield may be to allocate adequate budget for active watershed management programs and watershed protection that not only protects existing yield, but also maintains the present cost for treatment of supply from increases due to loss of watershed services. For example, the district does have the power to enter into voluntary agreements with landholders in the district’s watershed of its water supply to protect it, as protecting its water supply is certainly within the scope of a district’s obligation to provide water service to its customers. If the district identifies the costs of watershed management necessary to protect its water supply, then it could include this cost in its rate structure under its power to set rates to cover its cost of service. Also, the district can incorporate the cost of watershed protective practices as an integral part of its cost of service for which rates and developer charges must be set for full cost recovery. 7) Another means for reducing overall system risk might be to: (a) model the regional supply situation to determine overall system drought management and capacity capabilities and (b) based on the results of the study, invest in upgrading the capabilities for inter-district water transfer in times of supply emergencies. The potential is that with this type of analysis, it may be possible to delay the addition of expensive new capacity in the region by 5-15 years and still accommodate

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near-term projected growth at a fraction of the cost of rushing to add significant new capacity for the region. This type of modeling costs ~$100,000 to accomplish, but if it delays new capacity construction even by a few years, could potentially pay for itself many times over. One firm that is capable of conducting such modeling is Hydrologics out of Raleigh, North Carolina. 8) The district may also wish to consider forward contracts with Tracy City and/or Big Creek for guaranteed future supply, or explore the option of cost sharing for new supply with these utilities as a means to develop least-cost alternatives for regional supply augmentation. 9) Given the uncertainties regarding climate, safe yield calculations, demand forecasts, and regional cooperation on supply availability and augmentation, it may be most prudent to maintain Lake Dimmick, below the first two feet, as emergency supply only, given the asymmetry of outcomes to the district’s customers should a drought emergency extend longer, be more severe, or appear more frequently than the 2007 D4 drought experience and the district deplete its primary supply to a greater extent than during this last drought. 10) As conditions change such as knowledge concerning demand projections, land-use in the watershed, capacity availability, use of Dimmick for emergency supply, and/or climate related nonstationarity, safe yield should be updated. However, based on what I have learned from participating in this study, I would recommend that the district not engage in another linear-modeling safe yield study as was conducted for the district in 1973, 1993, and now in 2008, but consider instead a risk management study that models drought management and risk management strategies, given alternative supply options. This is the type of modeling that Hydrologics’ OASIS modeling software, for example, is capable. This type of modeling may provide especially useful before the district investing many millions of dollars in any expensive new supply capacity.

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S T U D Y
SUPPLY SOURCE

Y I E L D

C O M P A R I S O N S
1993 SAFE YIELD/ MAXIMUM YIELD (AVERAGE GPD) IN 1904TYPE DROUGHT BASED ON UNCALIBRATED MODEL /690,000 [750,000 in 1973 study] /1,057,000

2008 SAFE YIELD/ 2008 SAFE YIELD/ MAXIMUM YIELD (AVMAXIMUM YIELD (AVERAGE GPD) IN 2007ERAGE GPD) IN 2007TYPE DROUGHT BASED TYPE DROUGHT BASED ON CALIBRATED MODEL ON UNCALIBRATED MODEL Inflow from watersheds of 275,397 /878,521 /900,493 O’Donnell & Jackson reser[549,714] (3) voirs only (and top two feet of Dimmick) Inflow from watersheds of 482,384 /1,085,507 O’Donnell & Jackson & Dimmick, (and top two feet of Dimmick) (4) Inflow from watersheds of 482,384 [corrected] O’Donnell & Jackson & /1,515,644 Dimmick (and all of Dimmick) (5)

2008 SAFE YIELD/ 2008 SAFE YIELD/ 1993 SAFE YIELD/ MAXIMUM YIELD (AVMAXIMUM YIELD (AVMAXIMUM YIELD (AVERAGE GPD) IN AVERAGE ERAGE GPD) IN AVERAGE ERAGE GPD) IN AVERAGE PRECIPITATION BASED PRECIPITATION BASED PRECIPITATION BASED ON CALIBRATED MODEL ON UNCALIBRATED ON UNCALIBRATED MODEL MODEL Inflow from watersheds of 556,411 /1,159,534 570,000 /1,183,863 O’Donnell & Jackson reservoirs only Inflow from watersheds of 966,192 /1,569,315 O’Donnell & Jackson & Dimmick (and the top two feet of Dimmick) Inflow from watersheds of 966,192 /1,999,452 O’Donnell & Jackson & Dimmick (and all of Dimmick)
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SUPPLY SOURCE

Safe Yield is the maximum average daily demand (ADD) the supply can withstand under the precipitation assumptions given without depleting all supply in the supply reservoirs under consideration.
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Maximum Yield is the maximum average daily demand (ADD) the supply can withstand under the precipitation assumptions that consumes all inflow from the watersheds and all supply in the reservoirs under consideration.
3 Assumes

that during the year water is pumped from Jackson to O’Donnell until both reservoirs are dry, then the top two feet of Dimmick is pumped for withdrawal at O’Donnell until the top two feet are exhausted. Maximum Yield = annual production during 2007 + water remaining at end of 2007 drought (~100 days @ 321,819 ADD based on reservoir data) + top two feet of Dimmick storage (Dimmick was full at end of 2007): (117.464 mg + 32.182 mg + 51 mg) = 200.645 mg/365 da = 549,714 gpd [not 878,521] vs. 1993 W.A. Wauford study result of 690,000 gpd for less severe drought.
4 Assumes

that during the year water is pumped from Dimmick to Jackson to O’Donnell, until both O’Donnell and Jackson are dry and the top two feet of Dimmick is exhausted.
5 Assumes

that during the year water is pumped from Dimmick to Jackson to O’Donnell, until all three reservoirs, Jackson, O’Donnell, and Dimmick are dry.

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