AMWUA Blog

Oct 21 2019Share

Let’s Talk About the CAGRD

By Warren Tenney

When a difficult situation or issue spurs a diverse range of reactions, too often people do their best to dodge the subject or ignore it, like an elephant in the room. In Arizona’s water arena, that is the case with the Central Arizona Groundwater Replenishment District (CAGRD). The CAGRD is the responsibility of the Central Arizona Water Conservation District (CAWCD), the same entity that operates the Central Arizona Project (CAP).

With the recent release of a comprehensive and informative analysis of the CAGRD by ASU’s Kyl Center for Water Policy, there is a new opportunity for dialogue about the CAGRD, its impact on how Arizona manages its water, and its role in where and how development occurs. Having had the opportunity to review it, I strongly believe this analysis should be read by anyone interested in understanding water in Arizona, the complexity of the CAGRD, and how we must look at developing solutions to ensure CAGRD’s framework is sustainable. Up to now, conversations about the CAGRD have faltered due to the subject’s complexity and due to posturing of opposing opinions.

To better understand the CAGRD, you must first understand the State’s Assured Water Supply regulations, a set of laws, rules and policies, which require that before development can occur in an Active Management Area (AMA), including the Phoenix and Tucson metropolitan regions, the water provider must demonstrate they have enough water for at least 100 years. The key qualification is the water provider – city, town or private water company - must show they have, and will use, a renewable supply such as water from the Colorado River or Salt River, and not rely solely on groundwater. For long-term sustainability, the AMWUA cities not only secured allocations of Colorado River water but invested in the necessary infrastructure to put it to use. However, many landowners wanted to develop their lands but didn’t have access to renewable water supplies. They insisted that the State come up with an alternative method that would allow them to develop their lands and meet the proposed Assured Water Supply requirements. Thus, the CAGRD was created in 1993.

So how does the CAGRD work?

  • To develop land that is not served by a water provider with a 100-year Designation of Assured Water Supply, you must show that you have a 100 years of actual groundwater supply underneath your land. In general, the groundwater that is used must be replenished or replaced with another water supply by the CAGRD, not by the developer or water provider.
  • To develop your land, you pay what some may call a nominal enrollment and activation fee to qualify your land under the CAGRD.
  • Tax BillAfter development, the future homeowner pays the CAGRD a fee, in perpetuity, through their property tax to replenish the groundwater that was pumped.
  • The CAGRD has three years to find renewable water supplies and then replenish the groundwater pumped. The replenishment can occur anywhere in the AMA, not just where the groundwater was actually pumped.

Up until now, CAWCD staff overseeing the CAGRD have successfully ensured the CAGRD has met its replenishment obligations. Nevertheless, from its inception, concerns exist about the sustainability of CAGRD’s structural framework.

  • The CAGRD can’t turn anyone away. CAWCD cannot set limits. Meaning no matter how many lands want to develop that are not served by water providers with a 100-year Designation of Assured Water Supply, the CAGRD is responsible to find them renewable supplies to offset the groundwater pumped.
  • New renewable supplies are hard to find. The CAGRD must acquire the water necessary to meet the long-term growth of its obligation to replace pumped groundwater. Recent efforts to purchase water from Colorado River users have faced strong resistance. Also, the CAGRD no longer has access to excess Colorado River because of shortages on the River.   
  • Groundwater depletion is exacerbated. CAGRD’s framework permits groundwater to be pumped first and then replenished afterward anywhere in the AMA. This can lead to serious depletion of local aquifers as CAGRD enrollment grows.
  • CAGRD member homeowners pay an open tab. The CAGRD’s financial structure will be weighed down as costs to try to acquire dwindling water supplies increase. Those rising costs are paid as an assessment on the homeowner’s property tax bill.

It is vital that we grapple with these concerns now and not wait until the issues are exacerbated. Unfortunately, tough conversations about the CAGRD have historically been sidelined in favor of simplistic banter over whether it is good or bad. Some entities see the CAGRD as a critical institution that has been instrumental in generating economic development in Central and Southern Arizona. While other stakeholders fear that the unintended consequences from the CAGRD will eventually undermine the Groundwater Management Code. Caught in the middle is CAWCD, which has to deliver Colorado River water to its existing customers, but also must plan for the replenishment needs of CAGRD members it is not permitted to turn away.

In the end, the Kyl Center’s CAGRD analysis does an excellent job of acknowledging the water challenges linked, directly and indirectly, to the CAGRD. It provides the Arizona water community with the incentive to start an open honest dialogue about how we can sustain and ensure the longevity of the CAGRD. To begin this discussion, all stakeholders - CAWCD, the Governor, Legislators, Arizona Department of Water Resources (ADWR) as well as developers, homebuilders, private water companies, and municipalities - need to signal their willingness to be part of the process to take a hard look at the CAGRD. Together we need to deliberate the CAGRD’s structure, what we want from it, and look at both the positive and negative consequences that have arisen since its inception in 1993. It is in our collective interest to address the CAGRD to ensure everyone has a secure water supply now and into the future.


For 50 years, Arizona Municipal Water Users Association has worked to protect our member cities’ ability to provide assured, safe and sustainable water supplies to their communities. For more water information visit www.amwua.org.


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