BILL ANALYSIS Ó
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|SENATE RULES COMMITTEE | SB 555|
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THIRD READING
Bill No: SB 555
Author: Wolk (D), et al.
Amended: 4/16/15
Vote: 21
SENATE NATURAL RES. & WATER COMMITTEE: 8-0, 4/14/15
AYES: Pavley, Stone, Allen, Fuller, Hueso, Jackson, Monning,
Wolk
NO VOTE RECORDED: Hertzberg
SENATE APPROPRIATIONS COMMITTEE: 7-0, 5/28/15
AYES: Lara, Bates, Beall, Hill, Leyva, Mendoza, Nielsen
SUBJECT: Urban retail water suppliers: water loss management
SOURCE: Author
DIGEST: This bill requires urban retail water suppliers to
submit an annual water loss audit report to the Department of
Water Resources (DWR) beginning in 2017. This bill requires DWR
and the State Water Resources Control Board to establish rules
related to the water loss audits and to establish water loss
performance standards.
ANALYSIS:
Existing law:
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1)Requires all urban water suppliers to prepare and adopt an
urban water management plan (UWMP).
2)Requires UWMPs to be updated every five years. The 2015
update of UWMPs are due July 1, 2016.
3)Requires UWMPs to include, among other things, a description
of the service area of the supplier, the identity and quantity
of water resources, and water use projections.
4)Requires UWMPs to also include a calculation of the
distribution system water losses. The losses are required to
be reported in accordance with a worksheet approved or
developed by DWR through a public process. The water loss
calculations are required to be based on the water system
balance methodology developed by the American Water Works
Association (AWWA).
This bill:
1)Requires DWR, by January 1, 2017, to adopt rules governing all
of the following:
a) 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.
b) Validating a water loss audit report prior to submitting
the report to DWR.
c) Submitting a water loss audit report to DWR, including
the method and timing.
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2)Requires 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.
3)Requires every urban retail water supplier, by July 1, 2017,
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:
a) Increase the validity of data entered into the final
audit report;
b) Reduce the volume of apparent losses; and
c) Reduce the volume of real losses.
4)Requires DWR, if it finds any final audit report to be
incomplete, unvalidated, unattested, or incongruent with known
characteristics of water system operations, to deem the report
incomplete and return it to the water supplier. Requires a
water supplier whose audit is returned by DWR to resubmit a
completed audit within 90 days.
Background
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" 2001
statutes (SB 610 (Costa, Chapter 643) and SB 221 (Kuehl, Chapter
642). Compliance with the Act is a requirement to receive state
funding.
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Comments
1)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 San
Francisco Public Utilities Commission's experience.
(Secondary Research For Water Leak Detection Program And Water
System Loss Control Study, December 2009). Consequently, it is
not clear whether those estimates of 840,000 acre feet per
year (af/y) real losses and 350,000 acre feet per year af/y
economically recoverable real losses are reasonably accurate
or not.
2)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
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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.
3)Who validates? This 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? This bill is silent
on these questions.
4)How does this relate to UWMP Act requirements? Last year, SB
1420 (Wolk, Chapter 490, Statutes of 2014) 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 is not clear whether future plans will
simply report an agency's last five annual audits required by
this bill, or if the future plans would have to present some
other water loss analysis.
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FISCAL EFFECT: Appropriation: No Fiscal
Com.:YesLocal: No
According to the Senate Appropriations Committee:
One-time costs of $400,000 from the General Fund to DWR to
develop the rules guiding the water audit reports.
Unknown ongoing costs, but likely in the range of $150,000 to
$200,000, from the General Fund to review audits annually,
provide technical assistance to urban water suppliers, and
update the water audit report regulations every five years.
SUPPORT: (Verified6/1/15)
California League of Conservation Voters
Clean Water Action
Coastal Environmental Rights Foundation
Friends of the River
Heal the Bay
Natural Resources Defense Council
Planning and Conservation League
San Diego County Water Agency
Sierra Club California
Sonoma County Water Agency
Wholly H2O
OPPOSITION: (Verified6/1/15)
None received
ARGUMENTS IN SUPPORT: The author asserts that "it is
essential that all California communities use existing water
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supplies as efficiently as possible.
"Despite the availability of free audit software and the
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."
Prepared by:Dennis O'Connor / N.R. & W. / (916) 651-4116
6/1/15 16:16:54
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