1. richard.hallett@gmail.com Page 1
CVRD Water Efficiency Plan has a major flaw resulting in bad conclusion
Overview
The Comox Valley Regional District’s Water Efficiency Plan says that there is an urgent need to cut our
water usage by 27% to avoid exceeding our water license level within five years. Largely based on that
statement the city of Courtenay, the town of Comox and the Electoral Areas have all indicated that they
are going ahead with expensive water conservation initiatives. The total cost of these plans exceeds
$4,500,000. And that is just the start.
The 27% figure was derived using the assumption that our use of water will increase at the rate of 2%
per year for the next 20 years. The Water Efficiency Plan even admits that our rate of increase has only
been 0.83% over the past 15 years but in spite of that it chooses to use the 2% figure. In fact, our
growth rate in the last 10 years has been near zero even with a population growth of 13.75%.
This is not the first time the Regional District has mislead the community about water. Last year they
were saying that we used twice as much water per capita as the national average. I pointed out, as did
several others, that this was not true. They were comparing our total usage to residential usage in BC
and that for all of Canada. Statements from the RD indicate that they now accept that our water usage
was not as bad as they had said. However they continue to include the incorrect data in the final
version of the Water Efficiency Plan.
The Comox Valley is in the enviable position of having a great water source. We only use 0.83% of the
flow from Comox Lake, an amount that BC Hydro calls “a drop in the bucket”. We live in an agricultural
and farming area. Using our water to grow flowers, fruits and vegetables is not a waste. Neither is
supporting our local dairy industry and even a brewery.
It is still a good idea to be water smart and to not waste water. However, the information provided here
indicates that the report and its conclusions should be re-examined. Plans to spend great amounts of
money should be put on hold pending such a review.

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Bad Assumptions lead to bad conclusions
The Staff Report – CVRD Water Efficiency Plan – May 4, 2009 Page 4 makes the statement that
Consumption forecasts are developed based on a 2% annual increase, as recommended by Koers
1
, from
the 2008 annual consumption of 8,145,190 m³. While the annual consumption has only increased by
0.83% annually since 1995, over the longer term since 1990, it has increased at 2.27% annually. The 2%
increase was deemed to be more conservative
2
for planning purposes. The plan includes a water
consumption reduction target of 27% by 2014 in line with keeping annual consumption below the CVRD’s
water license volume for the next 20 years. Should water consumption continue at current consumption
levels the 2% annual increase would result in regularly exceeding the licensed volume in 2014 and beyond.
The chart below reproduces the one in the Water Efficiency Plan. The gap between the blue dashed
curve and the green one is 27%, the amount the CVRD says we must reduce.
The amount of reduction of water usage, if any, depends on the goal and the quality of the forecast.
The goal used above was to keep our water usage below the licensed amount for the next 20 years.
1
Likely the 2% figure came from the 2002 Koers report which had to project usage using late 90s data. This was a
study to support an application for government funding towards water meters.
2
Exaggerated may be a better description

3. richard.hallett@gmail.com Page 3
0.83% would have been a much better choice
Using 2% as a water usage growth rate may have come from the 2002 Universal Metering study. At that
time there may have been such a growth. However the growth rate has been declining. See the next
page for a chart showing this.
The following chart shows the trend using the 0.83% average annual growth from the past 15 years as
mentioned in the Water Efficiency Plan. It is easy to see that with this trend we have many years to go
before we hit the licensed water usage.
The last decade
Here is a chart of the total water used and the population of water users. We have had a considerable
increase in the number of water users with only a minor increase in water use over the decade.
New homes had to meet the Water Smart changes to the building code. These require low flush toilets,
and water saving showers. New home tend to have smaller lot sizes which require less watering.
Multifamily dwellings, particularly high-rises, tend to be the most water efficient.
We have done remarkably well with our water efficiency.
6,000,000
7,000,000
8,000,000
9,000,000
10,000,000
11,000,000
12,000,000
13,000,000
Actual
License
CVRD Forecasted 2% growth
15 yr. trend 0.83% Growth

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There are three years in which the water use was particularly high and we exceeded our licensed
amount. That meant that we had to pay BC Hydro for the loss of electricity production.
The Water Efficiency Plan points out that these were dry years. There were also fires that required a
great deal of water. 2009 was also a hot and dry summer but we did not have a serious fire season and
our water usage was quite normal.
Conclusion
Most of the Water Efficiency Plan is based on the theory that we need a huge reduction in our water
usage. What has been presented here shows that to be incorrect. The Regional District, the city and the
town should take another look at the Plan. There are far better way to spend money than solving a
problem that does not seem to exist.
About the Author
Dr. Richard Hallett has a Ph.D. in Mathematics from UBC and spent most of his career at Selkirk College,
in the West Kootenay region of BC. He taught Mathematics, Statistics and Computing Science before
moving into senior administration posts.
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2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
PopulationServed
WaterUseincubicmetres Total Water Used & Service Population
Comox Valley Water Service