Latest proposals from DWR on California’s Water Efficiency Framework
Over 3 workshops, DWR revealed their most comprehensive outline yet of what will be required of urban water suppliers.
From November 12th through 17th, the Department of Water Resources hosted 3 workshops to discuss their proposed final recommendations for the standards and methodologies associated with the framework to “make water conservation a California way of life”. Beyond the specifics of the water use objective (WUO), DWR also offered a deeper look at the implications of the framework for water use in California that shed light on the size of the water use reductions we can expect to see in the next decade.
Outlining the full requirements for water suppliers would take more than a single blog post, so this article will focus on summarizing some of the key new developments and what they mean. For more details on what actions water suppliers will need to take, keep an eye out for future blog posts as we continue to unpack the suite of guidelines that DWR is developing.
To start with, let’s take high-level view at the water use impacts that DWR predicts will result from the legislation.
Implications for Water Use in California
One of the requirements of the new framework is that it results in lower per capita water use than the 20x2020 targets set by SB X7–7. To estimate whether the proposed standards meet this goal, the DWR team developed a tool called the “Urban Water Use Objective Analyzer” to model the impact of different standard choices on water use.
The chart at left from the Nov. 12 workshop shows that if every supplier used exactly the amount of water prescribed by their WUO, then water use would be 7 GPCD lower than the SB X7–7 targets. This is visible in the chart as “Objective Use”.
However, most water suppliers are already far below their SB X7–7 targets, as evidenced by the fact that current water use is shown at 137 GPCD — almost 14% lower than the 2020 targets. To account for this, the DWR team looks at “Expected Use”, which assumes that suppliers whose use is currently greater than their WUO will drop down to their WUO, and suppliers whose use is currently lower than their WUO will continue using the same amount they currently do.
Under the proposed long-term standards from 2030 onwards, total expected water use is predicted to be 4.8% to 8% lower than current water use. These figures depend on whether the indoor standard reflects what is currently in the water code, or if it is updated with the current proposal to the legislature.
At the level of individual water suppliers, the amount of required water use reductions varies widely. Under the standards proposed to the legislature, two-thirds (66%) of the suppliers modeled have current use greater than their 2030 WUO.
Some of these are only slightly over the WUO, but a full 48% of suppliers modeled will need to reduce their water use by more than 10% in the next 9 years, with 18% requiring more than a 30% reduction. The suppliers in this last group will have their work cut out for them. Suppliers with these large required water use reductions should carefully evaluate all of the inputs for their water use and objective calculations to ensure that the numbers accurately reflect the level of efficiency on the ground, and are not caused by problems in their data.
There have been some mentions of a possible cap on the percentage of water use reduction that will be required, but details haven’t been confirmed. A cap on required reductions could help the small subset of suppliers that, because of special circumstances, end up with water use drastically larger than their WUO. For example, it is worth noting that for suppliers which exceed the 2030 WUO by more than 30%, the mean value of the exceedance is 55%, indicating that there are a few suppliers with even larger exceedances. These suppliers likely deserve special attention, either to correct issues caused by incorrect data, or to grant them the time and resources needed to effectively address the underlying causes of their inefficient water use.
Outdoor Standards
In addition to discussion of the water use implications, there were some important revisions to, and newly released information about the outdoor water use standards being proposed.
Most important, there now appear to be (at least) four different buckets where suppliers will need to allocate their landscape area, because different standards will apply to each.
Existing Residential and CII Landscapes
Both existing residential landscapes, and existing CII landscapes irrigated with a dedicated irrigation meter (DIM) will receive a proposed outdoor standard (ET Factor) of 0.8 that will drop to 0.65 in 2030. This updates the 0.7 factor initially proposed back in June and serves as DWR’s attempt to compromise between the interests of those calling for a more relaxed standard and those calling for a more stringent standard.
An important distinction between the residential and CII landscapes is that for CII landscapes, only irrigated area as measured by the supplier counts towards the objective. For residential landscapes, both irrigated and 20% of irrigable (not irrigated) landscape area counts toward the objective.
Residential New Construction
Residential landscapes at properties constructed after 2019 will receive a proposed outdoor standard of 0.55.
CII New and Rehabilitated Landscapes
CII landscapes at properties constructed or rehabilitated after 2020 will receive a proposed outdoor standard of 0.45. Importantly, this portion of the WUO will be calculated without subtracting effective precipitation from the reference evapotranspiration, which is the method used for all other landscapes.
Special Landscape Areas
Special Landscape Areas (SLAs) will receive a proposed outdoor standard of 1.0. SLAs are defined by MWELO as
…an area of the landscape dedicated solely to edible plants, areas irrigated with recycled water, water features using recycled water and areas dedicated to active play such as parks, sports fields, golf courses, and where turf provides a playing surface.
DWR is proposing to expand the definition of SLAs to include
- Engineered Slopes
- Supplemental water for ponds or lakes sustaining wildlife
- CII water use for maintaining water level or volume for public functions
- Public swimming pools
Variances
The list of possible variances that an agency can choose to apply for is large, and each has its own specific requirements and guidelines. What they all have in common is that in order to qualify for a variance, the volume of the unique use must exceed 5% of the suppliers total WUO. This 5% threshold for significance applies individually to each variance, meaning that a supplier may have substantial volumes of water going to several unique uses, but unless each of these passes the 5% threshold individually, then none of this water use may be added to the WUO. For example, a supplier could have a volume of water being used for livestock at 4.9% of their WUO, and an equal amount of water being used by seasonal residents, yet despite the sum of these amounting to 9.8% of the supplier’s WUO, neither of these uses would qualify for a variance.
Briefly listed here, the proposed uses of water for which a supplier may choose to request a variance are:
- Commercial And Noncommercial Agricultural Use
- Water Used For Dust Control For Horse Corrals And Animal Exercising Arenas
- Use Of Water During Emergency Events
- Use Of Evaporative Coolers
- Populations Of Horses And Other Livestock
- Landscaped Areas Irrigated With Recycled Water Having High Levels Of Total Dissolved Solids (TDS)
- Use Of Water To Supplement Ponds And Lakes To Sustain Wildlife
- Fluctuations In Seasonal Populations
A variance for use of water for medical devices (e.g. at home dialysis machines) is being deferred until a later date when these machines achieve higher market saturation.
Some of these variances will require substantial data collection and calculation efforts to satisfy the propose guidelines, so it would be wise for suppliers to consider carefully whether it is worth it for them spend the time to try to qualify. It seems feasible that a supplier could invest significant time to calculate the volume of water going towards one of these uses, only for it to fall short of the 5% threshold for significance.
CII Performance Measures
Most of the CII performance measures are still being determined, and we should have more clarity on what will be required in January. The one performance measure that DWR is making recommendations on now is for a CII Classification System.
DWR proposes to require suppliers to classify 20% of their CII accounts per year according to a classification system they have developed. Suppliers are not required to integrate these classifications into their billing system, though doing so may be helpful if possible. This means that a simple spreadsheet “crosswalk” would be acceptable, though a more sophisticated software system that allows suppliers to tie classifications to other customer and water use data would enable more powerful analysis of water use trends, and support hypothetical future reporting. [Keep an eye out for possible CII classification support in the CaDC Analytics software in the future!]
Suppliers will need to report their progress towards classifying their CII accounts, but the current legislation does not require water use reporting according to these categories. However, DWR can’t rule out that this classification system might make its way into other urban water reports (such as the Electronic Annual Report (EAR)) in the future.
Next Steps
- Comments on all of DWR’s proposals so far are due by COB on Nov. 24, 2021.
- DWR will be providing the “lite” version of their guidelines and methodologies to the SWRCB in December.
- Technical reports, variance-specific method recommendations, and proposals for CII DIM thresholds and in-lieu technologies are coming in January.
- Final guideline document and recommendations for CII performance measures will be coming in February.
IMPORTANT NOTE: The comments above reflect my interpretation of the materials presented by DWR and should not be considered legal advice. The California Data Collaborative does not represent, and is not employed by the DWR in any capacity. All decisions regarding how to comply with the regulations should be based on the guidelines that are ultimately approved by the State Water Resources Control Board.
