HomeMy WebLinkAbout2021-12-09; California Water Use Efficiency Standards and Reporting (Districts All); Gomez, PazTo the members of the:
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Dec. 9, 2021
CMWD Board Memorandum
To: Carlsbad Municipal ater istrict Board of Directors
From: Paz Gomez, Deputy C r, Public Works
Via: ger
Ccarlsbad
Municipal Water District
Memo ID #2021225
Re:
Vicki Quiram, General an
Scott Chadwick, Execut ve
California Water Use Ef cy Standards and Reporting (Districts -All)
This memorandum provides information on Senate Bill 606 (SB 606) and Assembly Bill 1668 (AB 1668)
and updates on the California Long Term Water Use Efficiency (WUE) Standards that the Carlsbad
Municipal Water District (CMWD) will be required to reach in upcoming years.
Background
In 2017, the California Department of Water Resources (DWR), the State Water Resources Control
Board (State Water Board) and other state agencies jointly released a report entitled, Making Water
Conservation a California Way of Life Implementing Executive Order 8-37-16. Based on this report, in
2018, SB 606 and AB 1668 were signed into law to provide a long-term framework for water
conservation and drought planning in California. These statutes require the DWR and the State Water
Board to develop new standards for the following uses:
1. Indoor residential water use
2. Outdoor residential water use
3. Outdoor commercial, industrial and institutional {CII) water use
4. Water loss
5. Variances for other specified local uses, for example seasonal impacts of tourism
6. Bonus Incentives, for example potable water reuse
The WUE Standards being developed will set an upper limit on the total amount of water that a retail
agency, like the CMWD, can serve to its customers. The WUE Standards do not limit a customer's
individual water use. To fully plan, develop and implement the new framework, the DWR and the State
Water Board have been working closely together in collaboration with stakeholders to develop the
new WUE Standards. The DWR formed the following 2018 Water Conservation Legislation workgroups
to obtain stakeholder input during the WUE Standards development:
• Urban Water Management Guidebook Workgroup
• Landscape Area Measurement Workgroup
• Wholesale Water Loss Workgroup
• Standards, Methodologies and Performance Measure Workgroup
• Water Use Studies Workgroup
• Annual Water Supply and Demand Assessment Workgroup
Carlsbad Municipal Water District
5950 El Camino Real I Carlsbad, CA 92008 I 760-438-2722 t
Board Memo -California Water Use Efficiency Standards and Reporting (Districts -All)
Dec.9,2021
Page 2
The CMWD staff have been participating in these meetings and coordinating with the San Diego
County Water Authority (SDCWA) and its member agencies, as well as with other water and
wastewater professional organizations, to learn and comment on the upcoming regulations related to
the WUE Standards. The derived formulas for calculating the WUE Standards that the DWR is expected
to recommend are complex and controversial. The DWR is expected to make their recommendations
to the State Water Board by the first quarter of 2022. The State Water Board will then go through its
regulatory process to consider adoption of the WUE Standards by June 30, 2022.
Discussion
Currently, water agencies develop and report total water use targets in their Urban Water
Management Plan (UWMP). These targets have been developed in response to the Water
Conservation Act of 2009, SB x7-7, in order to reduce per capita use by 20% by the year 2020. As
shown in the CMWD UWMP that was submitted on July 1, 2021, the CMWD's calculated 10-year
historical baseline (1999-2008) total water use was 259 gallons per capita per day (gpcd) and the 20%
reduced total water use target for 2020 was established at 207 gpcd. The CMWD's actual total water
use reported for 2020 was 135 gpcd, which met and exceeded the SB x7-7 target.
Under the new WUE Standards, water supply agl:!ncies will replace the current targets with their newly
calculated urban water use objective (UWUO). The UWUO is the sum of the following standards:
1. Aggregate residential indoor use
The residential indoor only standard applies to single family and multi-family housing units
within a water supplier's service area. The standard is based on a gpcd metric. There are indoor
residential use standards in the current statutes, SB 606 and AB 1668, but the DWR is
recommending new standards.
Average Indoor Residential Standards set in SB 606 and AB 1668
Starting Year Indoor Residential Standard (gpcd)
2020 55
2025 52.5
2030 50
The DWR Proposed New Indoor Residential Standards
Starting Year Indoor Residential Standard (gpcd)
2020 55
2025 47
2030 42
2. Aggregate residential outdoor use
The residential outdoor standard applies to single family and multi-family housing units within a
supplier's service area. The outdoor standard will be based on an equation which uses concepts
such as evapotranspiration, irrigation efficiency and landscape area for a supplier's total
residential landscapes.
Board Memo -California Water Use Efficiency Standards and Reporting (Districts -All)
Dec. 9, 2021
Page 3
In January 2021, the DWR provided the CMWD with a total square footage estimate of the total
residential landscape area. The CMWD staff reviewed, corrected and provided feedback to the
DWR in March 2021. The CMWD staff expect to receive the final residential landscape area in
late December 2021. After the CMWD staff receive the final residential landscape area and
other data inputs provided by the DWR, the residential outdoor use standard can be calculated.
3. Aggregate commercial, industrial, and institutional (CII) outdoor use
The CII standard applies to commercial, industrial and institutional outdoor water use. The CII
standard will also be based on an equation which uses concepts such as evapotranspiration,
irrigation efficiency, and landscape area for a supplier's total Cl! landscapes.
The CMWD does not currently have enough information to calculate the CII standard. The CII
standard will require data inputs from the DWR and the city's designated Cl I landscape areas.
The CMWD is responsible for mapping the CII landscaped areas and expects this to be an
intensive effort by staff and/or a consultant.
4. Aggregate water loss
SB 55 currently requires urban water retail suppliers to submit an annual validated water audit.
The water loss standard is expressed in gallons per connection per day or gallons per mile (of
pipe) per day depending on the supplier's size. The State Water Board's model calculated the
CMWD's 2028 water loss target to be set at 21.54 gallons per connection per day. In 2020, the
CMWD reported 5.28 gallons per connection per day for real losses.
5. Aggregate variances
The aggregate variance standard is for water supplier agencies with unique uses that can have a
material effect on an urban retailer water supplier's water use. The DWR recommended
variances for the following unique uses:
• Commercial and noncommercial agriculture
• Dust control
• Emergency events
• Evaporative coolers
• Horses and other livestock
• Irrigation with high total dissolved solids (TDS)
• Maintaining lakes and ponds
• Seasonal populations
Water suppliers with these unique uses in their service area will need to apply to the State
Water Board for a variance. Qualifying for any of the variances requires meeting defined,
specific requirements and extensive supporting data . If granted by the State Water Board, the
variance will be added to the overall UWUO.
The CMWD will apply for the seasonal population's variance.
Board Memo -California Water Use Efficiency Standards and Reporting (Districts -All)
Dec.9,2021
Page 4
6. Bonus incentives
The bonus incentive is for water suppliers that deliver potable recycled water or deliver water
from a groundwater basin, reservoir or other source augmented by potable reuse water. This
does not apply to the CMWD.
The following summarizes the most recent regulatory and CMWD work:
UWMP
• April 2021-The DWR released the UWMP Report Guidance document
• July 1, 2021-The CMWD submitted the five-year UWMP to the DWR (to be
updated/submitted every five years)
• Nov. 16, 2021-The DWR presented the 2021 Annual Water Supply and Demand Assessment
(shortage assessment) draft guidance
Water Use Efficiency {WUE} Standards
• January 2021-The DWR sent estimated residential landscape area measurements (LAM) to the
CMWD
• March 2021 -The CMWD submitted corrected LAMs to the DWR
• Nov. 12, 2021 -The DWR presented Standards, Methodologies and Performance Measures
draft guidance to stakeholders
• Nov. 16-17, 2021-The DWR presented WUE Standards Draft recommendations to
stakeholders
• Nov. 24, 2021-The DWR closed the formal comment period (the CMWD sent comments on
Nov. 24, 2021, see Attachment A)
• Nov. 30, 2021-The DWR submitted recommendations to the Legislature on Residential Indoor
Standards
• Dec. 2, 2021-The State Water Board presented water use efficiency standards impacts on local
wastewater management
• Dec. 3, 2021-The State Water Board presented water use efficiency standards impacts on
developed and natural parklands, and urban tree health
Next Steps
The CMWD staff will continue to attend the DWR workgroup presentations and coordinate with the
SDCWA and its member agencies, and water and wastewater professional organizations, in order to
stay informed on the progress of the recommendations. The CMWD will also provide local and regional
input and perspective on addressing the WUE Standards and guidance as the DWR and the State Water
Board efforts progress. In parallel with the SDCWA, on Nov. 23, 2021, the CMWD sent a comment
letter to the DWR expressing concerns with the recommended standards (Attachment A).
The DWR has indicated comments will be considered and subsequent WUE Standards
recommendations will be completed and submitted to the State Water Board in early 2022.
Board Memo -California Water Use Efficiency Standards and Reporting (Districts -All)
Dec. 9, 2021
Page 5
The State Water Board will adopt standards by regulation no later than June 30, 2022. Using the
adopted WUE Standards and the State Water Board approved variances, water agencies are required
to calculate and implement their individual UWUOs by Jan. 1, 2024.
The following summarizes future regulatory and CMWD work:
UWMP
• July 1, 2022 -The CMWD to submit Annual Water Shortage Assessment Report to the DWR (to
be updated/submitted annually)
Water Use Efficiency {WUE} Standards
• January 2022 -The CMWD expects final residential LAM acreage from the DWR
• February 2022 -The DWR expects to release UWOU calculation guidance documents
• Winter 2021-2022 -The DWR is expected to provide WUE Standards recommendations to the
State Water Board
• June 30, 2022-The State Water Board is expected to adopt WUE Standards for Outdoor
Residential, Outdoor CII DIMs, Variances and UWOU calculation guidance
• July 2022-January 2024 -The CMWD to calculate UWOU (calculated uses and apply for
variances)
• Jan. 1, 2024 -The CMWD to submit final calculated UWOU to the DWR and begin
implementation
• Jan 1, 2025 -The WUE Standards become more restrictive (e.g., Indoor residential use drops to
47 gpcd, outdoor residential and Cll landscape use to 80% of use)
• Jan. 1, 2027 -The WUE Standards to be fully implemented by the CMWD
• Jan . 1, 2030 -The WUE Standards become more restrictive (e.g., Indoor residential use drops to
42 gpcd, outdoor residential and Cl! landscape use to 65% of use)
Attachment: A. CMWD Board President letter to the DWR dated Nov. 24, 2021
cc: Geoff Patnoe, Assistant Executive Manager
Celia Brewer, General Counsel
Gary Barberio, Deputy City Manager, Community Services
Laura Rocha, Deputy City Manager, Administrative Services
Kristina Ray, Community & Engagement Director
Robby Contreras, Assistant General Counsel
Keri Martinez, Utilities Senior Engineer
Mario Remillard, Meter Services and Customer Service Supervisor
Nov.24,2021
Water Use Efficiency Branch
California Department of Water Resources
P.O. Box 942836
Sacramento, CA 95814
RE: Water Conservation Legislation Comments
Dear Water Use Efficiency Branch,
:;,'
(_earls bad
Municipal Water District
ATTACHMENT A
WUEStandards@water.ca.gov
The Carlsbad Municipal Water District (CMWD) appreciates the opportunity to submit written
comments to the California Department of Water Resources (DWR) on the recently released
information on the water use efficiency standard. The CMWD covers an area of 20,682 acres,
approximately 32 square miles, and provides potable and recycled water to most of the city of
Carlsbad. Water users within CMWD's service area are residential, commercial, industrial,
agricultural, and irrigation. In 2020, our residential water users accounted for 53% of total
demands while commercial accounted for 12% of total demands.
In general, CMWD requests that DWR consider the resources needed to develop and
implement the water use efficiency standards. The CMWD recommends that technical
assistance and financial resources be made available to water suppliers. The CMWD offers you
the following comments.
Guidance and Methodology
1. Provide technical assistance for calculating standard targets. This includes aiding in
measuring landscapes for dedicated landscape meters.
2. Provide technical assistance for variance applicability and acceptance. CMWD may be
eligible to apply for the following variances:
a. Significant landscaped areas with recycled water having high levels of total dissolved
solids (TDS); and
b. Significant fluctuations in seasonal populations
Outdoor Residential Water Use Standard Draft Recommendations
1. The CMWD appreciates the increase of the proposed Evapotranspiration (ET) Factor from a
0.7 standard to 0.8, and the higher ET Factor for recycled and special landscape areas.
2. The ET Factor of 0.65 proposed for 2030 will not support healthy irrigation practices for
many existing landscapes. At a minimum, the date for compliance with the lower ET factor
should be shifted to 2035, or a later more appropriate date, to allow water suppliers and
the state time to secure funding, build partnerships, and allow for technical advances
needed for landscape retrofits.
Carlsbad Municipal Water District
5950 El Camino Real I Ca rlsbad, CA 92008 I 760-438-2722 I www.carlsbadca.gov
3. Due to existing irrigation equipment and the age of landscaping, 0.80 and 0.65
Evapotranspiration Adjustment factor (ETAF) will have a significant impact on the existing
landscapes in our area. Much of the development in our area occurred prior to MWELO
being implemented. Requiring the quick and complete replacement of this landscape will
put an undue burden on our community. For communities like ours, CMWD asks that
consideration be given to the age and makeup of existing landscapes and the ETAF be raised
to keep our landscapes healthy and given our residents who have already reduced their per
capita water use by 48%. At this point our underserved communities will bear the burden.
Commercial, Industrial, and Institutional (CII) Recommendations
1. DWR's proposed recommendation of 20,000 square feet as a threshold for mixed use meter
conversion does not consider that dedicated meters do not guarantee water savings and is
frequently not cost effective. Converting meters can also be infeasible and require
significant on-site retrofits. The CMWD supports the alternative compliance recommended
by the Association of California Water Agencies {ACWA). The ACWA proposal requires the
conversion of meters only if they are irrigating more than an acre and using more water
than the outdoor water use efficiency standard. It also allows an alternative compliance
plan to reduce water use to meet the water use efficiency standard.
2. The CMWD also requests technical assistance for our agency as CMWD implements the
proposed CII classification. Guidance on the businesses in each category will be needed and
the CMWD also requests DWR recommend NAICS codes be made available to suppliers.
Thank you again for the opportunity to comment. If you require additional information, please
contact Vicki Quiram, General Manager at 760-603-7307, vicki.quiram@carlsbadca.gov.
Sincerely,
~$JV/
Matt Hall
Carlsbad Municipal Water District
Board President
cc: Scott Chadwick, Executive Director
Geoff Patnoe, Assistant Executive Manager
Paz Gomez, Deputy City Manager
Robby Contreras, Assistant General Counsel
Keri Martinez, Utilities Senior Engineer
Mario Remillard, Meters and Customer Service Supervisor