ACWA Bi-Monthly Water Conservation Meeting Update
Updates on key developments in water conservation regulations in California, including recommendations, workshops, and next steps by ACWA coalition. Details on proposed changes, timelines, compliance pathways, and industry recommendations.
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Bringing Water Together ACWA Bi-Monthly WUE Meeting Making Water Conservation a California Way of Life March 14, 2024 www.acwa.com Contact SonjaE@acwa.comto be on the ACWA WUE Distribution lists
Whats Happened & Next Steps 2022 o o o September: DWR Released Recommendations September: Governor Signed SB 1157 (Hertzberg) SWRCB Adopted Water Loss Regulation 2023 o o o o August 18: SWRCB Initiated Formal Rulemaking/ Released Draft Regulation October 4: SWRCB Workshop October 17: Written Comment Period November December 21: SWRCB hosted 21 meetings with five workgroups 2024 o o o o March 12: Revised Regulation March 20: SWRCB Workshop March 27: Written Comments Due Summer 2024: Regulation Adopted
ACWA Coalition Next Steps Consider Media Statements! ACWA to Circulate Draft Coalition Letter March 19 o Send logos to Sonjae@acwa.com by March 25 ACWA to Provide Oral Comments on March 20 o ACWA to release Alert & Member Toolkit Key Messaging: o Concise! o These are ambitious targets (add your 2040 if reduction required). o We appreciate and need the additional flexibility & time o We are ready to implement and plan to do X, Y, Z o Note any remaining concerns/ requested changes (reporting, compliance, etc.).
Key changes to the Draft Regulation 1. Urban Water Use Objective Outdoor Standards Timeline 20% INI Other Requested Modifications (Variances, MWELO references, SLAs, Bonus) Compliance Alternative Compliance Pathway 2. CII Performance Measures Timelines & Implementation Schedule Other Technical Changes 3. Reporting 975 new requirements
Changes: UWUO 1. Outdoor Standards Timeline Landscape Efficiency Factor DWR s 2022 Recs August 2023 Draft March 2024 Draft Residential CII w/ DIMs 0.80 0.80 Until 2030 Until 2030 Until 2035 0.63 0.63 Starting in 2030 Starting in 2030 Starting in 2035 0.55 0.45 n/A Starting in 2035 Starting in 2040 ACWA Recommendation (10/23): Modify the proposed timelines for the outdoor standards to provide an additional 5 years for all suppliers to achieve compliance. Proposed timelines are not reasonable, and do not support cost-effective compliance, and would not achieve the multi-benefits desired
Changes: UWUO 2. Inclusion of 20% irrigable, non-irrigated credit DWRs 2022 Recs August 2023 Draft March 2024 Draft Always include for everyone For suppliers that need it to comply, include until 2027 For suppliers that need it to comply, include unless and until landscape area is updated ACWA Recommendation (10/23): The draft Regulation should reflect DWR s recommendation with the inclusion of 20 percent INI. Suppliers would recalculate INI when DWR provides new LAM data. Consistent with legislation - The Conservation Legislation requires outdoor efficiency standards to apply to irrigable lands (Wat. Code, 10609.6 (2)(B)) Not a buffer. DWR statistical analysis conducted indicated that INI area is being irrigated at one fifth or 20% of the irrigable area
Changes: UWUO 3. Other Requested Modifications Variances o Every 5-years o Water use for any individual variance represents 5% or more of the associated budget for the UWO standard Standards decoupled from MWELO Special Landscape Areas Landscape Efficiency Factor 1.0 o Recycled water defined as 1.0 o Residential SLAs includes pools and spas Bonus incentive o Methodology for Direct Potable Reuse added
Changes: UWUO 3. Compliance with Objective to Begin 2027 DWRs 2022 Recs August 2023 Draft March 2024 Draft N/A Compliance deferred until 2025 Compliance deferred until 2027 ACWA Recommendation (10/23): Timelines proposed in the draft Regulation are not reasonable, do not support cost-effective compliance, The regulation is behind schedule and the legislative intended for a progress compliance schedule.
Updated Provisional Data Check the SWRCB s updated provisional data Click here to download and review data & 2030, 2035 & 2040 WUO https://www.waterboar ds.ca.gov/water_issues/ programs/conservation_ portal/water-use- explorer/
Changes: UWUO Compliance 3. Compliance with Objective to Begin 2027 August 2023 Version March 2024 Version 2040 Compliance 2035 Compliance CII PMs & Reporting 18% 71 31% 121 < 5% 9% 35 8% 31 5 10% 11% 43 13% 50 10 20% 21% 82 21% 84 20 30% 20% 81 15% 61 > 30% 21% 84 12% 49
Changes: UWUO Compliance 4. Alternative Compliance Pathway Eligibility Thresholds Required Effort Result for Supplier Income of Population Served Percentage Reduction March 2024 Draft < MHI >20% Reduce water use by >1% per year Plan to achieve its UWUO Supplier deemed in compliance > MHI >30% Reduce water use by > 2% per year Verify adherence to G480 standard Plan to achieve its UWUO Supplier deemed in compliance Reduce water use by > 2% per year August 2023 Draft < 80% of MHI > 20% Use of 0.63 for outdoor standards through 2040 Reduce water use by > 2$ per year Verify adherence to G480 & Tree City USA standards Have a program dedicated to climate ready trees Any > 20% DWR Recs The SWRCB consider a limited-time cap on the annual reductions that supplier would be expected to make ACWA Recommendation (10/23): Work collaboratively to develop an Alternative Compliance Pathway that allows suppliers that have an unreasonable or unattainable water use objective to be eligible for an alternative objective and/or extension of time to comply. Proposed alternative compliance does not address feasibility concerns and is not attainable for many.
Changes: UWUO Compliance 4. Alternative Compliance Pathway
Changes: CII Performance Measures 1. Timelines and Implementation Schedule CII Classification August 2023 Version March 2024 Version Classify 20% By 2026 NA Classify 60% By 2028 NA Classify 100% By 2030 By 2027 Maintain 95% 2030 onwards 2028 onwards MUM Conversion August 2023 Version March 2024 Version Identify MUM N/A 06/27 or 06/29 20% Convert or In-Lieu By 2026 NA 60% Convert or In-Lieu By 2028 NA 100% Convert or In-Lieu By 2030 06/2039 Maintain 95% Conversion or In-Lieu 2030 onwards 06/2040
Changes: CII Performance Measures 1. Timelines and Implementation Schedule BMPs August 2023 Version March 2024 Version Identify Disclosable Buildings 01/2025 06/2024 or Effective Date Top 20th % in each Classification Conservation Program Design & Implement 1. 06/2025 ID top 2.5% CII Users & Top 20% CII Users (Track 1) 2. 06/2027 ID top 2.5% CII Users & Top 20% CII Users in each Classification (Track 2) 3. 06/2029 ID CII Users based on Supplier Defined Thresholds (Track 3) Top 2.5% Customer Conservation Program Design & Implementation Non-Functional Turf Ban 07/2025 01/2027 Implement for 20% of the Following: 1. Disclosable Building Reporting 2. Top 20th %-ile in each Classification 3. Top 2.5% Customer Conservation Program By 2026 N/A
Changes: CII Performance Measures 1. Timelines and Implementation Schedule BMPs August 2023 Version March 2024 Version Implement for 60% of the Following: 1. Disclosable Building Reporting 2. Top 20th %-ile in each Classification Conservation Program 3. Top 2.5% Customer Conservation Program By 2028 N/A Implement for 100% of the Following: 1. Disclosable Building Reporting 2. Track 1, Track 2, or Track 3 By 2030 06/2039
Changes: CII Performance Measures 1. Timelines and Implementation Schedule Current Year Standard 2024 CY 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 Start End Indoor Residential 55 GPCD 47 GPCD 42 GPCD 2020 2024 2025 2029 2030 2045 X X X X X X X X X X X X X X X X X X X X X X X X X X Outdoor Residential 0.8 LEF existing landscapes; 1.0 SLA LEF; 0.55 LEF new landscapes 2024 2034 X X X X X X X X X X X 0.63 LEF existing landscapes; 1.0 SLA LEF; 0.55 LEF new landscapes 2035 2039 X X X X X 0.55 LEF existing landscapes; 1.0 SLA LEF; 0.55 LEF new landscapes 2040 2045 X X X X X X CII-DIM CII-DIM budget equal to actual deliveries 2024 2028 X X X X X 0.8 LEF existing landscapes; 1.0 SLA LEF; 0.45 LEF new landscapes 2028 2034 X X X X X X X 0.63 LEF existing landscapes; 1.0 SLA LEF; 0.45 LEF new landscapes 2035 2039 X X X X X 0.55 LEF existing landscapes; 1.0 SLA LEF; 0.45 LEF new landscapes 2040 2045 X X X X X X Water Loss Data Quality Questionnaire Pressure Management Questionnaire Assest Management Questionnaire Pressure Management Questionnaire Assest Management Questionnaire Real Loss Standard Compliance Apperant Loss Standard Compliance Water Loss Audit Leak Registry: 2025, 2026, 2027 Leak Registry: 2028, 2029, 2030 Leak Registry: 2031, 2032, 2033 Leak Registry: 2034, 2035, 2036 Leak Registry: 2037, 2038, 2039 Leak Registry: 2040, 2041, 2042 2023 2023 2023 2023 2024 2024 2026 2026 2027 2027 2026 2028 2026 2028 2020 2045 2029 2029 2032 2032 2035 2035 2038 2038 2041 2041 2044 2044 X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X CII PMS CII Classification CII Classification: Account Update 2024 2027 2028 2045 X X X X X X X X X X X X X X X X X X X X X X CII-MUM Conversion: 100% Compliance with Conversion or In lieu Tech CII-MUM Conversion: Maintain at least 95% compliance with Conversion or In lieu Tech CII-BMPs: Disclosable Buildings identification CII-BMPs: Identify Top 2.5% CII Users & Top 20% CII Users CII-BMPs: Identify Top 2.5% CII Users & Top 20% CII Users in each Classification 2024 2039 X X X X X X X X X X X X X X X X 2040 2045 2024 2024 2025 2025 X X X X X X X X 2027 2027 X CII-BMPs: Identify Inefficient CII Users based on Supplier KPIs CII-BMPs: Ban Non-Functional Turf Irrigation 2029 2029 2027 2027 X X CII-BMPs: Disclosable Building Reporting and Conservation Program implementation for Top 2.5% CII users, Top 20% of Each Category, or Inefficient CII Users Defied by KPIs (100%accounts) 2024 2039 X X X X X X X X X X X X X X X X CII-BMPs: Maintain 95% compliance Disclosable Building Reporting and Conservation Program implementation for Top 2.5% CII users, Top 20% of Each Category, or Inefficient CII Users Defied by KPIs CII-BMPs: Maintain 95% compliance on Conservation Program Implementation for Top 20% of Each Category 2040 2045 X X X X X X 2030 2045 X X X X X X X X X X X X X X X X Reporting Annual Report 2024 2045 X X X X X X X X X X X X X X X X X X X X X X
Changes: CII Performance Measures 2. Other Technical Changes MUM Conversion Large Landscape Threshold : acre of landscape MUM Identification schedule depends on area or volumetric evaluation 1 in-lieu technology instead of two BMPs: Outreach and Landscape (irrigation system inspection & irrigation scheduling training) BMPs Disclosable Building Reporting use the list of disclosable buildings, upon request of the building owner with ENERGY STAR Format CII Customer Identification schedule and Conservation Program Requirements Choose your own adventure Key Business Activity Indicator (Supplier Defined Threshold)
Changes: Reporting 3. Reporting Reports due by Jan 1st on a machine- readable form provided by the Board Fiscal Year Reporting o Conflict with other reporting requirements (eAR, water loss, etc.) o Indoor standards effective January 1st o Population value comes from eAR o Outdoor standards effective July 1st o How to adjust Water Loss for CY vs. FY? 975 - New Reporting Requirements o 975(a)&(e) supplier must submit to the Department and the Board (pgs 46 & 47)
Changes: Reporting 3. Reporting 975 - New Reporting Requirements (continue) o (d)(1)(A)(iii) and (iv) Reporting of 90th percentile SFR & MFR customers volume for what purpose & what statutory requirement? o (d)(2) Excluded CII, other, & ag water use to be reported, despite not being in the UWUO o (e)(1) Start reporting July 2025 on CII classifications (972), but 972 has this begin July 2027 o (e)(2-4) Estimated annual water savings with In-Lieu Technologies & BMPs Why? How? Imprecise and impractical, hence it was taken out of the UWUO Water use varies so much; multiple BMPs, how to estimate water savings? Key Business Activity Indicators (KBAI) how best to determine Track every BMP on offer to every CII customer is overly burdensome
WANT MORE INFORMATION? For more information: For more information: Chelsea Haines Regulatory Relations Manager Association of California Water Agencies chelseah@acwa.com To participate in ACWA s Working Group or Bi-Monthly WUE Meetings: Sonja Eschenburg State Relations Assistant Association of California Water Agencies sonjae@acwa.com Visit CalWEP s What the Framework Blog: https://calwep.org/framework-updates/
