All Methods

Limitations

Our purpose in using this indicator is not to compare communities against each other and we understand that a comprehensive plan does not detail every policy or program within a community. There are a number of limitations associated with this indicator:  

1. Assumptions that can be drawn from a comprehensive plan  
2. Individual community use of a comprehensive plan  
3. Year of plan update   
4. Differing state statutory requirements

Assumptions that can be drawn from a comprehensive plan: Comprehensive plans are not all-encompassing policy documents, and communities do water policymaking primarily through other processes, such as Water Management Plans or individual ordinances and budget items. We therefore cannot claim to fully understand the water policies of any CRB community from its comprehensive plan alone. To this end, additional Indicators homing in on particular water policy areas are being explored.   

Individual community use of a comprehensive plan: Each community uses its comprehensive plan differently—including not using or referencing it at all. Implementation of a comprehensive plan is incredibly difficult to discern, beyond matching up proposed policies with passed ordinances or budgeted programs and verifying with planning departments and elected officials the extent to which it is used and referenced. Some communities adhere to their comprehensive plans even years beyond initial writing and adoption. Some communities use just the land use map and zoning designations of the plan. Some communities do not use or reference their plans at all after passage. In a review of this scale, it is incredibly difficult to verify the use and importance of the comprehensive plan in each community reviewed.   

Year of plan update: Each comprehensive plan is updated according to its own schedule. Some states require that plans be updated on a particular timeline, such as every 10 years. Even then, individual community plans will have been initiated and updated according to their own schedules—and states do not tend to have an enforcement mechanism for this requirement, beyond making communities ineligible for certain funding pools if they do not have an updated comprehensive plan on file. The range of ages of comprehensive plans reviewed includes those from 1999 (Sante Fe, NM) to 2022 (Yuma, AZ). Further, California communities in particular—but not solely—tend to update their comprehensive plans in individual increments rather than as one cohesive project. The Los Angeles plan reviewed, for example, includes a Public Facilities and Services Element that appears to be from 1969, and a Housing Element adopted in 2021 and amended in 2022. In cases such as this, the water policies within the Housing Element are stronger and more modern than the whole description of water supplies in the 1969 Public Facilities and Services Element. One can also assume that cities like Los Angeles must rely on other water planning documents, like Urban Water Management Plans, for more updated information and planning related to water resources in the community.   

Differing state statutory requirements: Each state has different enabling legislation and statutory requirements for comprehensive plans. Arizona has required a water element within comprehensive plans since the early 2000s. Utah has newly passed (2022 legislative session) a requirement for water elements. The other Colorado River Basin states do not have clear mandates for the inclusion of water within comprehensive plans. Communities within those states thus are likely to pay more attention to the other topics that may be mandated by state statute—though this does not prevent them from incorporating water anyway. Pettit and Shah (2021) go into detail about the discrepancies in planning requirements across the United States.

Evaluating Water Integration in Comprehensive Plans

The method for evaluating water integration into comprehensive plans was tested and refined between the years of 2017 and 2019. An initial test framework was created based on a literature review and refined with expert input, then tested across 159 comprehensive plans. These tests revealed limits and opportunities that were applied to a new framework created through additional literature review, a crosswalk of topics within that literature review, and peer review. The framework—used in this evaluation and further explained below—has been applied to 135 plans to date.

Topics within the Comprehensive Plan Review –Comprehensive plans are evaluated for inclusion of water according to 20 categories across three topic areas:  

Each topic is given an individual score from 0 to 3, then aggregated into its category, which is then aggregated into its overall evaluation.  

Breakdown of values that determine topic quality based on the average 

Scoring System for Comprehensive Plan Review 

Plan language is collected in an Excel spreadsheet and sorted into the relevant topic and score.

Rules for Sorting Plan Language:  

Rules should be considered in the following hierarchy but used according to what is most appropriate to the specific plan language under review.   

1. Plan language is assigned to the most specific topic it is applicable to. Ex: “Integrate sound water conservation and reuse systems into new and updated public facilities” should be categorized as Building/Plumbing Policies.
2. Plan language is assigned to the topic that most relates to the end-use of water. Ex: “All large turf areas (e.g., schools, parks, golf courses, etc.) should use reclaimed water or other approved rain harvesting techniques for irrigation purposes” should be categorized as Landscaping/Irrigation Policies.
3. When plan language includes several topics under a general auspice, the more general category is used. Ex: “The City shall promote water conservation in landscaping for public facilities and streetscapes, residential, commercial and industrial facilities, including use of water-conserving fixtures (low water usage) and low‐water‐use plants” should be categorized as General Water Conservation.
4. If plan language is applicable to multiple topics, and no other language or policies are present to account for those policies, the same language may be counted for multiple topics. Ex: “The City has water block rates to create an affordable water cost to customers” can count for both Water Financing and Water Equity if no other plan language is present for these.