EH&S Information You Should Know About

A 3-Part Discussion of Arizona's Leading Current Water Issues

May 2018 VOL 16 No. 7

Nicholas R. Hild, PhD.

It has occurred to me since the Environmental Journal has become an ONLINE publication that it gives us the opportunity to deliver information in a variety of ways, not being limited to a few hundred word essay-type of format. It is a medium that truly provides a bully pulpit---(i.e. if you are too young to know what that means, you can google it…but it's pretty much what bloggers are already doing in presenting their own biased point of view about whatever topic)---but in this Journal, we are still all about presenting 'factual' and 'scientific' information based on credible sources and citations that are from the peer reviewed and credible scientific literature.

Nonetheless, the format we can use varies so we are no longer constrained to deliver our information in the form of an essay so I thought I would deliver this "article" as a plethora of different EH&S topics that have caught my attention over the past few months, many of which you might not know about, particularly if your main source of current information comes from social media. Some of these topics may be a little unusual---maybe even a little weird---but others offer serious concerns for EH&S professionals trying to work under the ever-changing chaotic constraints of a federal EPA that is being controlled (or 'not') by a climate-change-denying administration that is seemingly bent on setting back environmental progress in virtually every way possible---air, water/wastewater, solid/hazardous waste management---so, I hope some of these revelations will be beneficial; read on:

1. Wastewater-to-Potable-Drinking-Water And Other Fun Environmental Stuff

What's more fun than contemplating drinking water that was once wastewater?  Eeeuwwweee…. But first, something you need to know: one of those factual and reliable sources of environmental information mentioned above, is a web site called, a subset of which is Water Deeply (Link: that is a forum for issues of water pollution, supply, and distribution. In March, one of the subjects Water Deeply focused on was the use of treated wastewater as potable drinking water in Arizona. It is one of those controversial topics that, sooner or later, most of the southwestern states will have to deal with as drought-stricken drinking water sources continue to dry up and municipalities look for alternatives that mother nature (i.e. spell that 'climate change') forces upon us.

According to most climate change scientists, the time window for addressing this part of the climate change equation is rapidly closing and finding alternative sources of life-sustaining water will not be easy. What it also means is that EH&S professionals will be faced with making recommendations that will, no doubt, result in heated debate, political posturing, and criticism of the 'science' that drives water policy and water treatment technology schemes, especially as decisions are focused on reclaim and reuse priorities for wastewater. Thus, it is important to begin dealing with this issue as soon as possible, especially here in Arizona where it appears likely that we face more years of drought in the next decade and beyond.

On March 7th, 2018, Water Deeply interviewed Chuck Graf, long-time chief hydrogeologist and water expert at the Arizona Department of Environmental Quality (ADEQ). Not surprisingly, Chuck confirmed what EH&S professionals have known for years: Arizona has been reusing treated sewage for almost a century now, although only for irrigation primarily of non-edible crops like cotton and alfalfa and landscaping grasses and trees in street medians and golf courses. And some cities are sending their municipal treatment wastewater to reinjection fields where it replenishes the aquifers from which potable water is withdrawn, treated, and put into the distribution system. What is not as well known, however, is that a new set of State rules are now in place which will allow highly treated wastewater (emphasis on 'highly treated') to be piped directly into homes and businesses in the not-too-distant future. first reported this in their March Online edition but I want to share the information from the Water Deeply site directly with the EH&S professionals who read the Journal here:  We, in the profession, have long known that the next and ultimate step in dealing with the impending short supply of drinking water in Arizona is direct wastewater-to-potable-water reuse. This is the situation in which wastewater is treated so thoroughly that it meets Federal, State, and local municipal drinking water standards, and is then pumped directly into the drinking water distribution system. Texas was the first state to have a program that allowed direct wastewater-to-potable water programs on an emergency basis (i.e. where there were no other possible alternative sources available), but their program did not have a permanent set of rules for general applicants to reuse wastewater as potable drinking water. Chuck Graf also mentions in the interview, that California (always a leader in environmental programs), also has already put a draft direct wastewater-to-potable-water program together but evidently has not completely vetted it yet; read the interview below.

Thus, in January of 2018, Arizona became the first state to reach that benchmark, adopting a complete regulatory approach to direct potable reuse. On the site, Water Deeply (WD) recently published their interview with Chuck Graf, principal hydrogeologist at the Arizona Department of Environment Quality, where he explained more details about Arizona's new regulations. The following interview Q & A are taken directly from that Water Deeply (WD) interview (03/07/18):

WD: It's been a long road getting to this point with recycled water in Arizona, hasn't it?

C. Graf: In Arizona, we've been using reclaimed water for a long, long time. In fact, our first rule regarding reuse of reclaimed water was back in 1972. I don't know if that was a first in the nation, but it was probably in there somewhere. Actually, we started using reclaimed water back in 1926. And that was at Grand Canyon National Park, when they built a wastewater treatment plant specifically to reuse treated wastewater for steam locomotives and toilet flushing. And they still use it for toilet flushing and landscape irrigation in a much-improved treatment plant.

When they built the first treatment plant in Phoenix in 1931, they actually started distributing that reclaimed water for agricultural irrigation way back then. So it was already being used by the time first rules came into existence in 1972. Then in 2001, we greatly modified our rules for reclaimed water. Arizona probably reuses somewhere above 50 percent, and maybe as much as two-thirds of our treated wastewater.

WD: What do the new direct potable use regulations allow?

C. Graf: We started revising the 2001 regulations a few years ago. The first installment of those rules was adopted on January 1 of this year. The big part that's under this umbrella now is what we call "purified water for potable use." Now we can issue a permit for a facility that does advanced treatment on reclaimed water, and produces water that's suitable for putting in a drinking water distribution system. 
Our new rule says the source water for this advanced reclaimed water facility would have to go through a multistage, multi-barrier treatment process with controls, real-time monitoring, a whole lot of microbial monitoring and chemical monitoring. And the output from that facility is drinking water, and it could be put into a drinking water system.

WD: What's the demand for this type of permit?

C. Graf: We know of no utilities out there that are waiting at the door to come in. The big thing, though, is by having this rule in place now, that utilities and communities can think about maybe this is something we could do in the future and start evaluating this. Because, I think, for any utility to develop a real plan is going to take a couple years with high-level consultant help. By then we should have our final criteria in place, which will probably be early next year, we hope. But if somebody did come in now, we could actually entertain that application.

WD: Where is Arizona on this compared to other states?

C. Graf: Texas is taking applications and issuing permits on kind of a case-by-case basis. And they've actually issued a couple permits. When they had the big drought there, in Big Spring, Texas, in particular, their reservoir ran dry and they had essentially no water. They had to treat their wastewater and put it in the drinking water system. 

The California approach (yet to be finalized) has put in place very detailed specs on what's involved with doing direct potable reuse. So I think the California approach is at one extreme, where you just have a lot of detail. It's a very prescriptive approach. 
What Arizona wanted was a merging of the two. We don't want to leave out innovation by making the approach too prescriptive. But we want some detail there.

WD: In this context, what is the future of indirect potable reuse?

C. Graf: A number of big cities are doing indirect potable reuse, where they kind of use an environmental barrier: The treated wastewater is mixed with groundwater or surface water, and then you treat that mixture before it goes into the drinking water system. One of the arguments against that is you've treated this wastewater to an incredibly high level, and then you're mixing it with surface water again, which is actually way lower quality. A lot of people are now saying it just makes more sense to start reusing that treated wastewater directly.

WD: Are consumers ready to start drinking treated wastewater straight from their taps?

C. Graf: I think once these direct potable reuse plants go in, the technology we're going to be using is so high that people are going to start demanding some of that technology in normal treatment plants. People talk about emerging contaminants, and a lot of surface water in the U.S. is influenced in some way by upstream discharges by wastewater treatment plants. You can go to almost any surface water and you can detect some of these chemical constituents – personal care products and pharmaceuticals – at these low levels and I'm sure we're drinking them now.

The reason we looked at changing the rule is because the technology is here now. We can treat it to any clean standard we want. Also the real-time monitoring technology is there, too, so that you can monitor critical indicators at critical points in the process. That's important, rather than having to culture a sample and wait 16–18 hours for a report. The combination of those two give us confidence that these plants can be built and operated properly.

Special Note: Thank you, Chuck, for all you have done over the past decades at ADEQ for the betterment of the Arizona environment and our children's, children's, children!

2. Water Farming For Future Arizona Cities

…And now, to the next topic on the Journal ONLINE, a very timely and appropriate topic you should know about: Water Farming For Future Arizona Cities. Thanks again goes to for posting portions of the following report. I have added a few pertinent comments and clarifications for our Journal readers where appropriate. The following introduction is an example:

As a direct impact of climate change, the continuing drought has cities in Arizona asking the question,
"…in the face of future population growth (i.e. and increasing demand for potable water), how will municipalities find an assured water supply as rivers and groundwater aquifers continue to diminish?"
If other municipalities follow the lead of Arizona's largest cities, one answer is to 'buy' water now dedicated to agricultural production in and from rural Arizona farms and ranches although, as the following report shows, that may not be a popular solution for the farmers and ranchers who's water is being "sold".

Western Arizona Eyed As Water Source For Major Metro Areas 
A week into her appointment last fall as a Mohave County supervisor in western Arizona, Lois Wakimoto heard the words that would consume her since: We have a water problem.

The entity that sends Colorado River water throughout Arizona wants to buy farmland in her district that includes Mohave Valley, pay farmers to fallow it and redirect the water to the state's most populous areas where housing developments are booming.

The program would be the first in the state to move water from agricultural users along the river to central and southern Arizona, and local residents are opposing it.

"They want to take what they say is excess because we're not using it and store it for their future growth--- we look at that and say, 'what about our future growth?'" Wakimoto said.

The Central Arizona Groundwater Replenishment District doesn't need Mohave County's approval to proceed but plans could be delayed if the county government sues as planned.

The replenishment district, part of the Central Arizona Project, delivers 30,000 acre-feet of water annually to aquifers in Pinal, Pima and Maricopa counties, but expects that figure to at least triple as new housing is built. An acre-foot is the volume of water that is required to fill one acre of land with water one foot deep. In metric, that's 1,233 cubic meters and in the English system, that is 325,851 gallons or about enough to supply a typical family for a year with potable water.

The district is state-mandated to look for new water sources. Its portfolio includes water leases from an Arizona tribe and a private utility, storage credits, river water, and, potentially, the small town of Quartzsite.

Without more water, "there would be a fairly significant impact to the economy of the state of Arizona," said district manager Dennis Rule.

The 2,200 acres (890 hectares) of farmland in western Arizona's Mohave Valley Irrigation and Drainage District could add 5,500 acre-feet (6.8 million cubic meters). The $34 million deal is far from final, needing approval from the Mohave Valley Irrigation and Drainage District board, the state water agency and the Interior Department.

But talk of it has raised tension among residents and the board that oversees the seven farms and the 14,000 acre-feet (17.3 million cubic meters) of water tied to them that includes coveted senior water rights.

Public attendance at the district's monthly meetings generally is light but now dozens show up, even when the sale isn't on the agenda. Minutes into the February meeting, one man asked what was on everyone's mind: "Why does Phoenix want our water?"

Wakimoto, who comes from a farming family, took a front-row seat. She's urged residents to write letters, held town halls and questioned the board's motives.

"We are a community that has really all of a sudden realized that our entire future and the legacy we leave our children is at stake," she said.

Long-term fallowing programs around the Colorado River basin have benefited big cities like Los Angeles and San Diego and not Arizona cities.  So some are asking, even if farmers agreed to "sell", how would they be sure the water actually was provided to Arizona cities?  

The Central Arizona Groundwater Replenishment District paid farmers in Yuma $750 an acre to forego planting on parts of 1,500 acres (607 hectares) over three years, saving 21,500 acre-feet (26.5 million cubic meters) of water used to prop up Lake Mead. The district proposed extending the $3.2 million program but Yuma Irrigation District manager Pat Morgan said farmers declined.  

In Mohave Valley, the replenishment district has proposed fallowing up to half of the 2,200 acres (890 hectares). Farmers there mostly grow cotton, wheat and alfalfa. The deal won't work unless the Mohave Valley Irrigation and Drainage District allows water to leave its boundaries.

Under a draft resolution, the water couldn't leave forever. Board Chairman Chip Sherill said the district also wants assurances it doesn't lose out if a shortage is declared on the Colorado River.

Farmers use most of the district's Colorado River supply, with some reserved for growth, Sherill said. "We have a sufficient amount of water with Mohave Valley to take care of our water needs for many, many years to come."

The Mohave County Board of Supervisors has set aside $20,000 to draft a lawsuit against the irrigation district if a water transfer passes and bought 15 acres (6 hectares) of farmland there to establish legal standing.
If the replenishment district's proposal succeeds, water savings would be diverted upstream and sent through canals to aquifers around Phoenix and Tucson.

"This board will be transferring wealth from Mohave County to central Arizona," said county lobbyist Patrick Cunningham. "We think that is flat-out bad policy. It's wrong. This water should stay where it's reserved."

Perri Benemelis, the replenishment district's water supply manager, said the prospect of a lawsuit is disappointing. She believes everyone can benefit under the right terms.

"We're trying to implement our program in a responsible way," she said. "If we go after water supplies, and they have an adverse effect in the community, we're not going to be able to do the next transaction." (Seems easy for a bureaucrat to say, doesn't it?)

The whole concept of buying up water rights from Arizona's rural/agricultural areas for the benefit of city dwellers of the future, seems destined to negatively impact major geographic areas of the state (and the people who live and farm there) for generations to come. Which leads to the obvious question, how do you measure the ways taking away water rights may "have an adverse effect in the community" in those areas where those rights have been terminated? It may take years or decades to determine the impact and in the meantime, what will be the effect on that population and on their children's, children's, children?

And now, to our final topic, keeping with our Water theme…

3. Arizona's Groundwater

A short topic you need to know about, again all about water supply in Arizona, this time it's about groundwater, a critical resource that is regulated by the Groundwater Management Act of 1980, signed into law by then Governor Bruce Babbitt. As you already know, it was the first State groundwater law and set the model for other states (and some Federal laws) and has not been amended or changed since it was promulgated.

This past legislative session, a few legislators tried to amend the Act to essentially allow groundwater to be drawn down in aquifers beyond what the safe 100 year assured supply level is specified in the Act. It was a somewhat convoluted bill fraught with a lot of (intentionally) moving parts, according to one environmental attorney familiar with the bill. Senate Bill 1507 failed (this session), but that does not mean it won't be brought up again in a future legislative session. And that is where you come into play---your expertise is needed to ensure we don't get bad environmental legislation---or, perhaps worse: legislation that poses a threat to our already threatened groundwater supply. And, that is especially true if our drought conditions continue and surface water supplies from the Central Arizona Project (i.e. the Colorado River, Lakes Mead and Powel) continue to fall in the coming years.

The reason you, as an EH&S professional, need to know about this is because we professionals need to be ever vigilant in observing our legislators on a daily basis (from January to June when the legislature is in session) in order to be a part of the process so necessary to ensure our fragile Arizona environment isn't negatively impacted in the long term by legislation that gets passed for the short term gain of a few. Again, we are in this for the long term and, as experts on the environment, we have the opportunity (and obligation) to fight for the interests of our children's, children's, children.


This area will be reformated at a later date.