BILL ANALYSIS Ó
SENATE COMMITTEE ON NATURAL RESOURCES AND WATER
Senator Fran Pavley, Chair
2015 - 2016 Regular
Bill No: SB 555 Hearing Date: April 14,
2015
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|Author: |Wolk | | |
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|Version: |April 7, 2015 |
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|Urgency: |No |Fiscal: |Yes |
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|Consultant:|Dennis O'Connor |
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Subject: Urban retail water suppliers: water loss management.
BACKGROUND AND EXISTING LAW
Under the Urban Water Management Planning Act (Act), all urban
water suppliers are required to prepare and adopt an urban water
management plan (UWMP). Updated every five years, the plans
include, among other things, a description of the service area
of the supplier, the identity and quantity of water resources,
and water use projections. UWMPs help inform the public about
the water challenges faced by their local water supplier, the
suppliers' plans for addressing those challenges, and are the
basis for making water availability determinations under the
"show us the water" statutes (SBs 610 & 221 of 2001).
Compliance with the Act is a requirement to receive state
funding. The 2015 update of UWMPs are due July 1, 2016.
Last year, the Legislature passed and the Governor signed SB
1420 (Wolk). That bill, among other things, added to the Act a
requirement that beginning with the 2015 update, UWMPs are to
contain a calculation of the distribution system water losses.
The losses are to be reported in accordance with a worksheet
approved or developed by the Department of Water Resources (DWR)
through a public process. The water loss calculations are to be
based on the water system balance methodology developed by the
American Water Works Association (AWWA).
PROPOSED LAW
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This bill would:
1.Require DWR, by July 1, 2016, to adopt rules governing all of
the following:
Conducting standardized water loss audits by urban
retail water suppliers in accordance with the method
adopted by the American Water Works Association in the
third edition of Water Audits and Loss Control Programs
Manual M36 and AWWA Free Water Audit Software version 5.0.
Validating a water loss audit report prior to submitting
the report to DWR.
Submitting a water loss audit report to DWR, including
the method and timing.
1.Require DWR to update the water loss rules every five years
and no later than six months after the release of any
subsequent editions of the American Water Works Association's
Water Audits and Loss Control Programs Manual M36.
2.Require every urban retail water supplier, by July 1, 2016,
and annually each year thereafter, to submit a completed and
validated water loss audit report for the previous calendar
year as prescribed by DWR. Each water loss audit report is to
be accompanied by information, in a form specified by the
department, identifying steps taken in the preceding year to:
Increase the validity of data entered into the final
audit report;
Reduce the volume of apparent losses; and
Reduce the volume of real losses.
1.If DWR finds any final audit report to be incomplete,
unvalidated, unattested, or incongruent with known
characteristics of water system operations, DWR would be
required to deemed the report incomplete and return it to the
water supplier. A water supplier whose audit is returned by
would be required to resubmit a completed audit within 90
days.
ARGUMENTS IN SUPPORT
The author asserts that "it is essential that all California
communities use existing water supplies as efficiently as
possible."
"Despite the availability of free audit software and the
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establishment of a Best Management Practice for water loss by
the California Urban Water Conservation Council (CUWCC), urban
water suppliers have been slow to realize the full potential of
water loss control. One reason for the slow adoption of water
loss control methods is the unreliability of water loss audit
data. One CUWCC study found that 35% of water audit data
submitted by California water suppliers was invalid."
"By requiring urban water suppliers to report system audit
results and directing DWR to set audit standards, while
providing the necessary technical assistance, water suppliers
will achieve effective water loss control and contribute to
California's water management, climate mitigation and climate
adaption goals."
ARGUMENTS IN OPPOSITION: None received
COMMENTS
Is Water Loss A Real Problem? It's hard to know. According to
the California Water Plan, in its discussion on urban water use
efficiency:
"The amount of water lost due to leakage in the
distribution system of the State's water suppliers is not
well known. This is largely due to the fact that not all
water suppliers perform regular water loss audits. If water
audits are not conducted, it is difficult for a water
agency to know the extent of its losses and unlikely that
the agency will implement practices to reduce these
losses." (California Water Plan Update 2013, Vol. 3, Ch. 3)
Proponents point to a 2011 study prepared for the California
Public Utilities Commission Energy Division titled "Embedded
Energy in Water Pilot Programs Impact Evaluation." Included in
that study was an evaluation of Southern California Edison's
(SCE) Leak Detection pilot program. However, the statewide
estimates of water losses and economically recoverable losses
reported in that study were essentially back of the envelope
calculations; based on year 2000 urban water use, "the commonly
quoted threshold for acceptable real losses in California of 10%
of volume supplied," and a 40% economically recoverable real
losses rate based on SFPUC's experience. (Secondary Research
For Water Leak Detection Program And Water System Loss Control
Study, December 2009). Consequently, it is not clear whether
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those estimates of 840,000 af/y real losses and 350,000 af/y
economically recoverable real losses are reasonably accurate or
not.
Do any other states require this? According to the Center For
Neighborhood Technology:
"In June of 2010, the Georgia Water Stewardship Act (the
Act) was signed into law in an effort to create a "culture
of water conservation" throughout the state of Georgia. One
of the main components of this legislation was a mandate
requiring that all utilities serving populations of 3,300
and above submit annual water loss audits utilizing the
American Water Works Association (AWWA) and International
Water Association (IWA) water audit methodology (M36)."
"Currently, Georgia has had 100% compliance from utilities
for every year that they have been required to submit the
AWWA water audits. It is interesting to note that some
utilities serving populations less than 3,300, while not
included in this mandate, are now using the auditing method
voluntarily after hearing positive anecdotes from their
larger system peers. The success of Georgia's program
provides an effective blueprint for other states and
agencies in how to begin providing support to their
utilities in moving forward with best practices in water
loss management." (Stepping Up Water Loss Control: Lessons
From The State Of Georgia, February 2014)
Besides Georgia, it appears that some states have water loss
detection requirements of one type or another. But none of
those states have programs as rigorous as Georgia's or as
proposed by this bill.
Who Validates? The bill requires DWR to establish rules for
validating the water loss audit report prior to submitting the
report to DWR. Who would that entity be? How with the
validating entity's cost be reimbursed? The bill is silent on
these questions.
How Does This Relate To UWMP Act Requirements? As noted in the
background, last year SB 1420 (Wolk) added water loss reporting
requirement to the Act. While the reporting requirements in the
Act are similar to that in this bill, they are not the same. It
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is not clear whether future plans will simply report an agency's
last 5 annual audits required by this bill, or if the future
plans would have to present some other water loss analysis.
6 Months To Adopt Rules? This bill would give DWR 6 months to
adopt rules regarding water loss audits. Under best of
circumstances, the administrative process for adopting rules or
regulations is about one year. The committee may wish to amend
this bill to give DWR a more reasonable amount of time to adopt
rules required by this bill. [See Suggested Amendment]
SUGGESTED AMENDMENT
On page 2, line 3, strike out "July 1, 2016" and insert
"January 1, 2017"
SUPPORT
Natural Resources Defense Council
Clean Water Action
Sierra Club California
OPPOSITION: None Received
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