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Santa Fe: Where Conservation Meets Demand

Introduction
There is a strong link between water and energy in municipal water distribution systems. “Between two and three
percent of the world's energy consumption is used to pump and treat water for urban residents and industry.” i Addi-
tionally, “the burning of fossil fuels to generate the energy used to supply water affects local and global air quality
and the resulting emissions contribute to already high levels of pollutants in the urban environment and the acidifi-
cation of lakes and forests.”ii Carbon dioxide contributes to global climate change and climate change is likely to re-
duce water tables and disrupt water supplies in many areas, making water even more costly and energy intensive to
obtain in the futureiii. Water efficiency is of particular interest for localities in dry, arid, or drought plagued regions.

One such city is Santa Fe, New Mexico. Santa Fe, an EPA WaterSense partner 1, has been practicing water conserva-
tion for several years and has notable programs underway. Two initiatives under the Water Conservation Credit Pro-
gram, principally the conservation contracts and retrofit rebates, create an excellent program model for a city wide
energy-focused program.

The Conservation City of the West

Santa Fe, meaning “holy faith” in Spanish, became the capital of the New Mexico province in 1610iv and is the fourth
largest city in the statev. With a population of 69,961vi, the city has a thriving mixture of Native American, Spanish,
and modern American cultures and holds the nation’s second largest arts market with a $1.6 billion annual arts
economyvii. The city also scores as highest2 elevation state capital in the United Statesviii.

Tourism plays a large part in the Santa Fe economy and “attracts one to two million visitors each year.” 3ix With the
combination of day visitors and overnight visitors increasing the city’s base population significantly and an elevated
water demand that follows tourism, it makes the city’s outstanding record on water conservation much more re-
markable.x

The City of Santa Fe is governed by Mayor David Coss, who was elected to serve in 2006 and residents are repre-
sented by eight4 City Councilors, two5 elected from each of the City's four council districts. The city government
holds meetings on the last Wednesday of every month. The ordinances of the City of Santa Fe are titled the Santa Fe
City Code (SFCC); ordinances pertaining to water regulations are found in Chapter XXV 6.

History of Water Shortages

The City of Santa Fe has limited water supplies. There are three water sources for City customers: the Santa Fe River,
the City well field, and the Buckman well fieldxi. Yet, a large amount of the city's water supply is dependent on un-
predictable precipitation; this affects the amount of water supply available - seasonally and annually - to the city and

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its water customers. In times of shortage or drought, the city has encountered serious challenges in meeting the de-
mands on the water system.

Since its purchase of the municipal water utility in 1995 7, water conservation has been a chief concern of the City
Council, who have “emphasized and effectively implemented8 a comprehensive and very aggressive water conserva-
tion drought management program.”xii In 2003, Santa Fe evaluated their water demand finding their already
strained supply would not meet current or projected demand. That same year, in an effort to lower peak demand,
the city passed an ordinance stipulating that new demand
must be offset by replacing old, high-flow toilets with low-
flow toilets that have the capacity of 1.6 gallons or less. This
was a very successful ordinance. After observing the resulting
water savings, the City Council knew the toilet rebate pro-
gram was only the beginning of Santa Fe’s water conservation
initiatives.

In 2005, the perfect storm of a significant building boom, a

mounting population, and nearly six years of drought re-
quired the city to impose emergency water conservation
measures that included restrictions on outdoor watering for
residential and commercial spaces; some community areas
Courtesy of Wikipedia Commons, Credit
were also restricted.xiv Additionally, under state statute re-
quirements9, Santa Fe submitted its Water Conservation and Drought Management Plan of 2005 10, combining multi-
faceted conservation methods, including important elements such as landscaping requirements, water use restric-
tions, water rate conservation incentives, water use audits, water offset for new development, and public educa-
tion.xv The conservation plan is set out through various mandatory city ordinances, which are conditions of munici-
pal water service.

With an estimated 79,62311 current residents, the city realized efficiency and conservation would be the most cost-
effective method to meet future demand.xvi

City Response: Resource Conservation

Much of the water demand on the city water system is offset through conservation contracts or retrofit rebates
from the Water Conservation Credit Program. However, before credit is given for conservation efforts, or rebates
are arranged, the city must have a baseline measurement of water usage; this is called the development water
budget. As a water plan, the development water budget is required for city water hook-up and lays the groundwork
for the conservation contracts, rebate programs, and water right transfers.

Development Water Budget

When a home owner or contractor wishes to connect to city water service, a development water budget must be
drafted; these are reviewed and approved by the Water Engineering Section of the city’s Water Division 12. A devel-
opment water budget must include the following information:

1. Description of all existing and proposed buildings on the land;

2. Description of all existing and proposed water fixtures and other water using devices/equipment to be in-
stalled or constructed on the land;

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3. Description of all proposed water uses proposed for this parcel of land, separated by indoor/outdoor use as
well as total area of proposed and existing landscape;

4. Quantification of gallons and acre-feet of the total proposed water usage on an annual basis.xvii

The applicant has the choice to allow the Water Division to calculate their water budget 13 or develop their own de-
tailed alternative water budget that must be supported by reliable data corresponding to a similar development pro-
ject. The alternative water budget must demonstrate that
their anticipated annual water use will be less than if based
on the Water Division’s standard formulas. Development wa-
ter budgets are submitted with land use applications to the
Land Use Department and forwarded to the Water Division.
Examples of land use applications are: development plans,
phased development plans, building permits, and secondary
plumbing permits14. Until the responsible applicant or con-
tractor’s development water budget15 has been approved,
building permits will be stalled.

After approval of the development water budget, the appli-

cant may obtain water through either the Water Rights Trans-
Courtesy of Michael Jaskolski, Credit fer Program or the Water Conservation Credit Program. For
residential use that requires more than ten acre feet per year
(AFY), the applicant must obtain water through the water rights transfer program; residential uses requiring less
than ten AFY, the applicant may obtain water through the water rights transfer program or water conservation cred-
its, or a combination of both.xviii

For non-residential development water budgets that require more than five AFY, the applicant must obtain water
through the water rights transfer program; non-residential uses that require less than five AFY may obtain water
through the water rights transfer program or water conservation credits, or a combination of both. xix Development
water budgets that have mixed uses16 requiring less than seven and a half AFY must obtain water through the water
rights transfer program; projects with more than seven and a half AFY may have a combination of water rights trans-
fer program or water conservation credits.xx

Water Conservation Credit Program

The Water Conservation Credit Program17 administers water conservation credits created through conservation con-
tracts or retrofit rebates at existing developed property within the city’s water service area where credits are used to
offset new system demands of small development projects.

Water conservation credits were created by the city to increase conservation and offset future demand to the water
supply system. Conservation credits18 may be created through two ways: a Water Conservation Contract or a Water
Conservation Retrofit Rebate.xxi A city water customer19 enters into a water conservation contract ensuring they will
save a certain amount of water throughout the year, with a minimum reduction of two one-hundredths AFY or 6,517
gallons per year.xxii Once the contract is in place, a resident or business implement various conservation measures
such as installing water saving showerheads, timed faucets, low-flow toilets, waterless urinals, replacing old appli-
ances with water-efficient units, or altering the landscape to native species that often require less watering. xxiii The
Water Division tracks the customer’s usage rates to ensure the savings are achieved and maintained, and then cred-

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its are deposited into the city water bank in the customer’s name for the amount of water they pledged to con-
serve.xxiv

Slightly different are the conservation retrofit rebates, where the city acquires conservation credits by installing wa-
ter saving retrofits, fixtures such as rain barrels, or water saving landscaping for commercial and residential custom-
ers.xxv There are three conditions for the rebate program:

1. The city must have confirmation or proof that the retrofit was in-
stalled;

2. Customers receiving the retrofit must allow inspections prior to, dur-
ing, and after the installation of said retrofit and, if necessary, provide old
appliances for collection and disposition of to ensure they are not used;

3. Once the city pays the rebate to the customer, the city deposits the
appropriate amount of water conservation credits into the city water
bank.xxvi

The resulting water conservation credits are often used for “resale to wa-
ter customers who exceed their allowed water usage under an alternative
development water budget or a water conservation contract.”xxvii The
Courtesy of David Prince most successful program was the Water Wise Santa Fe Replacement Toi-
let Program. It is no surprise that Santa Fe targeted toilets, since twenty-
eight percent of the water consumed in a home is used for flushing. xxviii The city gave away 5,508 residential and
2,559 commercial low-flow toilet20 to applicantsxxix. A 3.5 toilet can require as much as 27,300 gallons a year, while a
1.6 toilet requires only 7,80021 gallons, mitigating 19,500 gallons of water demand per toilet per year. xxx As of 2008,
the toilet retrofit program had offset 1,008 AFY since the program’s inception five years ago. xxxi
Figure 1.0 – Water Wise Toilet Retrofits, Source: City of Santa Fe, Sangre de Cristo Water Division. Water Update 2008.

The second option to obtain water in Santa Fe’s water utility is under the Water Rights Transfer Program. This can
only be done after the development water budget has been approved by the Water Division.

Water Rights Transfer Program

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The Water Rights Transfer Program is another means to acquire water rights, generally for a larger development pro-
ject. This is a costly and lengthy process. When an individual or contractor intends to purchase water rights 22, they
must notify the city, in writing, whether the water rights will be dedicated to a development water budget or desig-
nated for the city water bank.xxxii The city will review the water rights transfer application, which must include the
following:

1. The name and address of the current owner(s) and/or seller(s) of the water rights;
2. A description of the development project(s) that the wa-
ter rights will be used for, or a designation that the water
rights will be allocated to the city's water bank;
3. Proof of ownership of the water rights in the form of: a
declaration of water rights; the most recent change of owner-
ship form for the water rights; and any deeds regarding the
water rights in the county where the water rights are located;
4. A title search or title report for the property to which the
water rights are appurtenant;
5. Any permits, licenses, or court orders for the water rights,
with a description of the place and purpose of use and point
Courtesy of Michael Jaskolski, Credit of diversion for the water rights;
6. A copy of the agreement between the seller(s) and applicant under which the applicant intends to ac-
quire the water rights;
7. An affidavit from the seller(s) detailing the water rights are free and clear of any liens 23 and that no part
of the water right has been lost through abandonment or forfeiture; and
8. Other documentation the city may request related to the water rights.xxxiii
Following the submission of the documentation, the city will inform the applicant within sixty days whether the
transfer of the rights is feasible for the city and the AFY the applicant is granted. xxxiv In the event of a denied applica-
tion, the city will explain, in writing, the reasons why the water rights transfer is not feasible. After all the related
transfer fees24 are paid by the applicant, the water rights will be transferred into the Water Rights Transfer Program
in their name. At this time, the applicant must apply to the State of New Mexico Office of the State Engineer to
transfer the water rights to Santa Fe’s designated point of diversion in the Middle Rio Grande Basin. Santa Fe is listed
as a co-applicant on the state application and must also include the total number of AFY granted by the city. xxxv Ap-
proval by the Office of State Engineer is an even lengthier and judicious process, often taking several months, during
which time building permits may not be issued and has the potential to interfere with construction projects. xxxvi Af-
ter an extensive review process and numerous expenses, the city is issued a water rights transfer certificate for wa-
ter right transfers to the city permit.xxxvii The Office of the State Engineer will send a final permit to the city and the
Water Division will deposit the water rights in the city water bank in the applicant's name and issue a water rights
transfer certificate confirming the deposit.xxxviii It is at this final stage that the Land Use Department will “accept the
dedication of transferred water rights to meet an approved development water budget as shown on the water dedi-
cation form” and building permits will be approved.xxxix

With such an expensive and protracted process in acquiring and transferring water rights, it is simple to understand
why a great deal of new demand has been offset through the conservation contract and rebate programs.

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Enforcement, Measurement, and Verification

Program success is due to Santa Fe’s impressive enforcement efforts, particularly for the conservation contracts. The
city monitors the demand to the water utility system by ensuring contracts are fulfilled. If the Water Division finds
that a customer has exceeded their development water budget or water conservation contract, they will notify the
customer and begin to monitor their demand on a monthly basis.xl These rates will be compared to the same month
of the previous year’s usage to determine whether the customer has reduced their consumption and is in compli-
ance of their contract.xli Customers are given a 50% sur-
charge over the base rate of water on the excess water deliv-
ered over the annual budgeted or contracted amount of that
year.xlii If, after four months of monitoring, the customer is in
compliance with their water contract or development water
budget, the customer will be informed and will resume an-
nual monitoring; conversely, if the customer still exceeds
their water contract by ten percent or more, the Water Divi-
sion will notify the customer and, in the notice, include a re-
calculation of a new budget based on their actual consump-
tion over the period of non-compliance.xliii The notice will
also indicate the additional water credits or conservation
Courtesy of Michael Jaskolski, Credit credits required to meet the new budget. If the customer
does not transfer water rights, water credits, or conservation
credits to the city within ninety days to cover the additional demand, the Water Division will include a charge of the
current cost of the conservation credits on their next bill.xliv If this continues, the city will bill a 50% surcharge for the
water delivered over the course of the second year of the budgeted or contracted amount. The customer may, at
any time, transfer conservation credits, water rights or water credits to Santa Fe to meet their demand. However,
customers who fail to provide sufficient water rights, water credits, or conservation credits or to pay the cost of con-
servation credits and any additional fees will have their water disconnected. xlv It is important that large develop-
ments projects, such as apartment complexes, condominiums, or business parks that have adopted an alternative
development water budget or conservation contract give this information to buyers in a formal statement. This
statement must include the amount of water allocated to each lot, unit, or portion of the project and a description
of the penalties.xlvi

Santa Fe Water Bank

Santa Fe’s city water bank25 was a tool created to help the city manage their water resources more efficiently by ex-
amining system-wide supply and demand and assessing projected supply and demand. The water bank is an accu-
rate accounting mechanism that will assist the city government in managing its resources by providing stable, pre-
dictable, and adequate water supply and demand statistics. Another goal of the water bank is to ensure the city
maintains a minimum flow26 in the Santa Fe River to sustain a healthy riparian27 ecosystem.xlvii

On an annual basis, the Water Division must evaluate Santa Fe’s total water system supply and total water system
demand; this water budget report28 will be made available to the Public Utility Committee at every April meeting
and to the city council at its May meeting.xlviii This comprehensive report will aid Santa Fe in water resource manage-
ment from 2010 onwards.

The water bank contains available water from five29 resources and can be allocated according to the priorities deter-

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mined by the city:

1. The water bank will maintain at least three consecutive future years of annual water demand, and each
year’s allotted amount will be set aside into an affordable housing account;

2. Water available from the retrofit rebate conservation credits will be for sale to small development pro-
jects and twenty-five AFY will be reserved for sale to water customers who surpass their anticipated
demand based on their development water budgets or water
conservation contracts;

3. Water right permit offset requirements;

4. City projects including parks, opens paces, water for the

Santa Fe River, city facilities;

5. Other projects where Santa Fe is a partner;

6. Private or non-city public uses and projects that align with

other city priorities such as economic development, energy
efficiency, job creation, and community health.xlix

Consumptive use water rights, water credits, and water con-

Courtesy of Michael Jaskolski, Credit servation credits are all transferred into the water bank and
the Water Division manages the transactions. As an example,
when a water allocation has been approved by the city for a specific project, the Water Division will take the water
credits from the city’s account in the water bank and credit a special account for that project. l When it comes time
to apply the water credits, the developer withdraws the credits from the special account and applies them to an ap-
proved development water budget prepared for the project. This dedicated amount becomes part of the total water
system demand and will be included in the following year’s total system demand figures. li

Water allocations to the water bank are revolving. When water allocations are not dedicated to an approved devel-
opment water budget or building permit within two years after its deposited into the water bank, the city will absorb
the allocations into its city account and “the applicant may reapply for the previously allocated water credits when
the previously designated development project is ready to proceed to the appropriate stage in the development per-
mitting process.”lii

Shift the Focus to Energy

An added benefit of the water offset programs Santa Fe has initiated are the subsequent energy savings; it would be
an advantage for the city to calculate and include energy savings in all their water savings data they have dissemi-
nated, as it would generate another motivation for a residence to save water. Not only could a residence decrease
their demand and save money on their water bill, but the same would be true for electric; as water demand de-
creases, so does the energy involved in producing potable water and transporting it to the end user.

Yet another incentive to focus on energy is the importance in regards to sustainable development and climate
change goals. As Santa Fe is a partner in the Cities for Climate Protection (CCP) Campaign 30 and Sierra Club’s Cool
Cities Campaign31, they could easily build on the current water savings programs to meet emission targets. liii The
successful program models for the conservation credits and retrofit rebates could be replicated for energy. For in-
stance, Santa Fe or the local electric utility could create an energy savings contract for customers within

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their service territory and simply monitor their usage through the meter infrastructure already in place. This effort
would lessen greenhouse gas emissions and their impact on the global climate.

Along the same lines, the utility or city could provide efficiency rebates for replacing energy-hogging appliances,
such as clothes washer/dryer, tankless water heaters, freezers, or even installing new, efficient windows. A very suc-
cessful program similar to the Water Wise Santa Fe Replacement Toilet Program that focuses on energy is EPA’s
Change a Light, Change the World Campaignliv, which encourages people to replace an incandescent bulb for a com-
pact fluorescent light (CFL) bulb. The campaign educates indi-
viduals that one CFL will “save about $30 over its lifetime and
pays for itself in about six months; uses 75 percent less en-
ergy and lasts about ten times longer than an incandescent
bulb.”lv

These illustrations are only a few programs that Santa Fe

could employ to bolster support in city-wide energy conserva-
tion. With national climate change legislation imminent, state
and local governments will find themselves accountable for
action plans and policies to measure and mitigate green
house gases. Given that Santa Fe has been a leader in water
Courtesy of Michael Jaskolski, Credit conservation and, building on those successes, the city has
great potential for duplicating their accomplishments in the
field of energy.

Footnotes
1
Launched in 2006, WaterSense is an EPA-sponsored partnership program that seeks to protect the future of our nation's water supply by
promoting water efficiency and enhancing the market for water-efficient products, programs, and practices. www.epa.gov/watersense
2
Santa Fe is located at 7,000 feet (2134 m) above sea level.
3
Santa Fe was ranked No. 2 on the "10 Best Cities in the U.S. List" in 2004.
4
Currently the 2009-2010 City Council Officials are as follows:
District 1: Councilor Patti Bushee & Councilor Chris Calvert
District 2: Councilor Rosemary Romero & Councilor Rebecca Wurzburger
District 3: Councilor Miguel Chavez & Councilor Carmichael Dominguez
District 4: Councilor Matthew E. Ortiz & Councilor Ronald S. Trujillo
Additional information, such as biographies, are available on the City of Santa Fe’s Website: http://www.santafenm.gov/index.aspx?nid=72
5
Elections are held every two years and Councilors are elected to four year terms.
6
Santa Fe City Code can be found online through the city website, http://www.santafenm.gov or http://clerkshq.com/default.ashx?
clientsite=Santafe-nm
7
Santa Fe’s water utility was purchased from Public Services Company of New Mexico, now PNM Resources, Inc.
8
The City Council in 1996 and 1997, respectively, enacted the Emergency Water Regulations Ordinance (Ord. #1996-17) and the Compre-
hensive Water Conservation Requirements Ordinance (Ord. #1997-17). These ordinances were later repealed and modified with the policy
direction and decisions of the city council.
9
State statute: 1978 NMSA § 72-14-3.2
10
Santa Fe’s Water Conservation and Drought Management Plan of 2005 is available online at: http://www.santafenm.gov/
DocumentView.aspx?DID=534
11
As of 2009 and includes residents from the greater Santa Fe County, not just those located within the Santa Fe city lines.
12
Water Engineering Section website: http://www.santafenm.gov/index.aspx?nid=1150
13
The Water Division calculates water budgets using standard formulas drawing from historical water use rates.

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14
Unless the building permit is: 1) for a new development that is consistent with an already approved water budget, 2) less than 33% or less
of an existing building, 3) a remodel or addition with no new water fixtures or does not exceed 500 ft2, or 4) the building permit is a shell
only permit.
15
The Development Water Budget must cover water for the project and as well as a 9.8% cushion for water utility delivery requirements. 16
This 9.8% is allocated to community health and safety purposes (i.e. fire, fire hydrant testing, sewer flushing, line leaks, or water main
breaks).
17
When both commercial and residential uses are combined into one project, it is considered a “mixed use” development project.
18
The Water Conservation Credit Program is found under Article 25 §11 SFCC 1987.
A water conservation credit represents a fixed quantity of water expressed in acre feet per year (AFY) that is transferable within the city of
Santa Fe for annual usage.
19
Only citizens who have five years of maintaining their development or alternative development water budget may enter into a water con-
servation contract.
20
Ultra-low-flush (ULF) toilets use no more than 1.6 gallons per flush (gpf) rather than 3.5 to 7 gallons of water used by other designs.
21
Usage assumptions: 30 flushes per day and 260 days per year.
22
If water transfer is for a phased development, the notification must be done sixty days after the final approval by the land use depart-
ment, the planning commission or the governing body of the final subdivision plat.
23
If any liens, affidavit must include an explanation that they will be released before or at closing.
24
Applicant must reimburse the city for its hydrologic due diligence review of the water rights by paying the actual costs as evidenced by
invoices from consultants prior to the city's final written acceptance of water rights into the water rights transfer program.
25
A water bank is a mechanism designed to facilitate the transfer of water use entitlements from one location or use to another. A water
bank functions like an intermediary, or broker, similar in some ways to a financial bank that acts as a broker or clearinghouse between sav-
ers and borrowers.
26
A minimum flow is the limit at which further water withdrawals will cause significant harm to a river or stream and the related natural
environment. When a river or stream drops below its minimum flow, the aquatic life of that ecosystem can be harmed.
27
A riparian area is the interface between land and a stream. Plant communities along the river margins are called riparian vegetation, char-
acterized by hydrophilic plants. Riparian zones are significant in ecology, environmental management, and civil engineering because of their
role in soil conservation, their biodiversity, and the influence they have on aquatic ecosystems. Riparian ecosystems are under great threat
due to urbanization in watersheds throughout the U.S.
28
The Water Budget Report must include: 1) Current total water supply; 2) Total water demand; 3) Water System Annual Operating Plan,
estimating water production from supplies and how it will meet projected demand; 4) Water Resource Annual Management Plan, describ-
ing impacts on the city’s water resources resulting from the annual operating plan and any actions to mitigate such impacts; 5) Twenty year
supply-demand projection, including near and long term demands on the water system; 6) Any exceeded committed demand and the pre-
cise amount deficient; 7) Status of the city’s Water Conservation Credit and Water Rights Transfer Programs; 8) Quantification of all water
credits held in the city water bank.
29
As stated in the ordinance (Ord. #2009-38, §16), the five sources are: “1) the portion of surplus sustainable water supply in excess of com-
mitted demand that the governing body has transferred to the city water bank;2) City's water rights purchases and leases deposited in the
city water bank;3) Retrofit rebate conservation credits deposited in the city water bank under the water conservation credit program; 4)
Conservation credits donated to the city rebates under the water conservation credit program; and 5) Infrastructure projects allowing reuse
of water or return flow credits.
30
Following this first initiative and as a response to the adoption of the United Nations Framework Convention on Climate Change (UNFCCC)
by nations at the Earth Summit in Rio in 1992, the 1st Municipal Leaders Summit on Climate Change, held in New York in 1993, resulted in
the birth of the Cities for Climate Protection (CCP) Campaign.
31
Sierra Club's Cool Cities Program, led by volunteers around the country, is a collaboration between community members, organizations,
businesses, and local leaders to implement clean energy solutions that save money, create jobs, and help curb global warming. Since 2005,
over 1000 city and county leaders have made a commitment to cut their community's carbon footprint. More info: www.coolcities.us/

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References
i
Watergy Website. http://www.watergy.net/
ii
Id.
iii
Id.
iv
Santa Fe Official Website. Community Profile. http://www.santafenm.gov/index.aspx?NID=601
v
Wikipedia, Santa Fe, New Mexico. http://en.wikipedia.org/wiki/Santa_Fe,_New_Mexico
vi
City of Santa Fe, Housing & Community Development Department. Santa Fe Trends 2009. http://www.santafenm.gov/DocumentView.aspx?DID=3780
vii
Santa Fe Official Website. Community Profile. http://www.santafenm.gov/index.aspx?NID=601
viii
Wikipedia, Santa Fe, New Mexico. http://en.wikipedia.org/wiki/Santa_Fe,_New_Mexico
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City of Santa Fe, Housing & Community Development Department. Santa Fe Trends 2009. At 6. http://www.santafenm.gov/DocumentView.aspx?DID=3780
x
Id.
xi
City of Santa Fe, Sangre de Cristo Water Division. Water Update 2008. http://www.santafenm.gov/DocumentView.aspx?DID=4065
xii
City of Santa Fe. 2005. Water Conservation and Drought Management Plan for the City of Santa Fe.
xiii
Water Division, City of Santa Fe, New Mexico. 2008. Water Use in Santa Fe. http://www.santafenm.gov/DocumentView.aspx?DID=5017
xiv
Id at 1.
xv
Id.
xvi
City of Santa Fe, Housing & Community Development Department. Santa Fe Trends 2009. At iii.
xvii
City of Santa Fe, New Mexico. City Ordinance No. 2009-38, Development Water Budgets, §3(B)(1)(a)-(c).
xviii
Id at §3(E)(1)(a)-(f).
xix
Id.
xx
Id.
xxi
City of Santa Fe, New Mexico. City Ordinance No. 2009-38, Water Conservation Credit Program, §25(A).
xxii
Id at §25(C)(1).
xxiii
Id.
xxiv
Id at §25(C)(1)(b).
xxv
Id at §25(C)(2).
xxvi
Id at §25(C)(2)(a)-(c).
xxvii
Id at §25(D)(2).
xxviii
The Natural Resources Defense Council, Green Living: Green Living Guides, NRDC's Guide to Greener Living, http://www.nrdc.org/cities/living/gover.asp
xxix
Water Division at 13.
xxx
Flex Your Power. Commercial Sector, Product Guides: Toilets. http://www.fypower.org/com/tools/products_results.html?id=100139
xxxi
City of Santa Fe, Sangre de Cristo Water Division. Water Update 2008. At 16. http://www.santafenm.gov/DocumentView.aspx?DID=4065
xxxii
Id at §32(D)(2).
xxxiii
Id at §32(D).
xxxiv
Id at §33(A)-(E).
xxxv
Id at §35(A).
xxxvi
Id at §36(B).
xxxvii
Id at §36(F).
xxxviii
Id at §38.
xxxix
Id at §39(B).
xl
Id at §27(D)(1).
xli
Id at §27(D)(2).
xlii
Id.
xliii
Id at §27(D)(4).
xliv
Id.
xlv
Id at §27(D)(5).
xlvi
Id at §27(D)(6).
xlvii
Id at §15
xlviii
Id at §15.
xlix
Id at §16(D)(1)-(6).
l
Id at §16(E).
li
Id.
lii
Id at §16(F)(3).
liii
ICLEI. The City Climate Catalogue. http://www.iclei-europe.org/index.php?id=6917&cmd=shortlist&org_id=1831
liv
U.S. EPA, ENERGY STAR, Change A Light Campaign. http://www.energystar.gov/index.cfm?c=change_light.changealight_index
lv
U.S. EPA, ENERGY STAR, Products. http://www.energystar.gov/index.cfm?fuseaction=find_a_product.showProductGroup&pgw_code=LB

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