Stage 6 Stage
6 Water Rationing (Rule 166) is the response to “high risk” water supply
conditions and requires a 35 percent system-wide reduction. Stage 6 Water Rationing also enacts a
moratorium on water permits that propose to use public or private water use
credits. Restrictions on non-essential
outdoor water use may occur during this stage.
Restrictions implemented in previous Stages remain in force.
Stage 7 Stage
7 Water Rationing (Rule 167) is the response to “extreme” water supply
conditions and requires a 50 percent system-wide reduction. Restrictions on non-essential outdoor water
use may also occur during this stage.
Stage 7 includes a moratorium on use of portable and hydrant water
meters. Restrictions implemented in
previous Stages remain in force.
per capita plan
“Per capita” rationing was requested
repeatedly during the process of developing the Expanded Water Conservation and
Standby Rationing Plan (Regulation XV) in 1998.
Sources of input included comments at public hearings and discussions
with the Public Utilities Commission (PUC) staff, the
Technical Advisory Committee (TAC), the Policy Advisory Committee (PAC), and
the Citizens Conservation Committee (CCC).
The approved Plan (i.e. Regulation XV) employs a per-capita
conservation rate design. For
residential uses, the per-capita rate design has five sharply ascending blocks;
for other categories, there are two ascending blocks. The per-capita conservation rates are
census-based and assign a base rate to each customer that reflects the number
of persons in a home and the size of the property. Conservation is rewarded with a lower rate
block, and water use above the base rate significantly increases in each of
three top blocks. This increasing block
rate structure has been in place since 1997.
CAW will be requesting additional blocks for non-residential users in
its next General Rate Case filing.
During Stage 5 and higher
levels of water rationing, each residential user will be assigned an equal
portion of the water available to residential users. The strength of a per-capita rationing
system is that all residents are treated equally. Water rations for residential uses are based
on the overall number of residents in the system and the total rationed water
available to residential users. Properties
with large landscapes and two residents are given the same ration as smaller
properties with two residents.
Similarly, residents who had conserved water felt that they were
unfairly penalized using an across-the-board percentage reduction. After the 1989-91 rationing program
concluded, per capita rationing was perceived by the public as the only fair
way to ration residents in the future.
Similar to the residential per-capita
rations, non-residential users must also reduce according to the amount of the
overall water supply used. CAW tracks
monthly water use for the following non-residential water use categories:
Commercial, Industrial, Public Authority, Golf Course, Other, and Non-Revenue
Metered Use. The plan reduces water use
in each user category by the reduction amount corresponding to the Stage
implemented.
ACTIONS REQUIRED PRIOR TO PLAN IMPLEMENTATION
The following
actions must be implemented at least three months prior to consideration of
implementation of Stages 4 or higher:
·
Adopt revisions to
Regulation XV
·
Adopt a revised
enforcement ordinance
·
Provide
·
Obtain access
agreements with Water Distribution System Operators, including a process for
obtaining customer consumption and other data necessary to enforce a rationing
program
·
Begin Public
Outreach Plan for rationing program
·
Complete
computer programming necessary to implement and enforce water rationing
·
Design website
specific to the rationing program
·
Update water conservation
regulation to reflect current conservation standards
·
Identify and
obtain permitting compliance of mobile water distribution systems operators
·
Prepare job
descriptions and recruiting announcements for rationing staff
The following
actions should be authorized and occur immediately upon direction to implement
Stages 4 or higher:
·
Notify
·
Recruit and hire
rationing office staff
·
Secure office
space for staff
·
Purchase/lease
office equipment and furniture
·
Set up data management
systems and telephone systems
·
Seek
reimbursement from CAW for expenses related to MPWMD emergency rationing costs
(A.05-02-012, Special Requests 6 and 9)
PERSONNEL
Position titles and proposed salary ranges
Water Rationing Administrator Range 34
Senior Water Rationing Specialist Range
28
Water
Rationing Specialists I/II Ranges 18 and 22
Water
Rationing Technician Range 16
Office Specialists I/II Range 10 and 12
personnel costs
Water Rationing Administrator
(one position) - $87,838 annualized
Senior Water Rationing
Specialist (one position) - $79,431 annualized
Water Rationing
Specialists I/II/s budgeted at the I level (seven positions) - $67,960
annualized
Water Rationing
Specialists I/II/s budgeted at the II level (three positions) - $72,207
annualized
Water Rationing
Technician (five positions) - $65,987 annualized
Office Specialist I/II’s
budgeted at the II level (two positions) - $61,710 annualized
Estimated personnel costs
at full staffing (19 positions) are approximately $1,313,000, including
benefits. Costs include a temporary
reclassification of the Water Demand Manager to Range 41 for the extent of the
rationing program. Funding for the costs
of rationing are paid by CAW using a memorandum account approved under Special
Request 9 of the 2005 General Rate Case Decision A.05-02-012 and A.05-02-013.
staff training
Immediately
upon hire, rationing program staff will begin training overseen by the Water
Demand Manager, a Senior Conservation Representative or a Conservation
Representative II from the Water Demand Division. All staff will receive basic training related
to:
- General District functions and organization
- District and rationing office facilities
- Office equipment
- Reporting levels
- Rationing regulations
- Rationing data management systems
- Conservation regulations
- Non-Disclosure Agreement with CAW
- Customer service standards
In addition, specific
training will be done in the following areas as required to perform the functions
of the position:
- Data entry
- Hearing staff reports
- Ration adjustments
- Inspecting for Best Management Practices
- Water waste enforcement process
- General correspondence
D. space needs
This section is being
considered as a policy decision and text will be added after a determination on
the best way to address the space needs of a rationing office.
public
education and outreach
Public information
campaigns continue to be the most popular way of encouraging water users to
adopt water conservation behaviors during drought. Primary objectives include: (l) persuading
the consumers that they should conserve water, and (2) providing them with
information on how to do so. The joint
effort at public outreach by California American Water and the District has
been successful in reducing per capita water use on the
During drought periods,
it is crucial that the District, CAW, and other water distribution system
operators work together to communicate a consistent message regarding the local
water situation. It is also essential
that the message coincide with the implementation of the various stages of
rationing. During the previous
rationing, it was noted, “Haste in adopting the rationing program (the initial
ordinance was adopted just 19 days before it became law), made the provision of
public educational materials on a timely basis impossible. The implementation of water rationing did not
always coincide with the information getting out to the public.” For this reason, public education materials
and advertising must be developed as far in advance of rationing as possible
and maintained for immediate reproduction when needed.
During the 1989-91
rationing period, the theme was “Save Your Share.” This theme reflected early concerns about program
fairness. Stages 5 through 7 are about
fairness. Although the art-work is no
longer available for the previous ads, the District may want to breathe new
life into the old rationing theme and use the old material as the basis for
rationing ads. The advantage to using
old material is that it would substantially reduce advertising development
costs. Examples of the previous
advertising campaign are found in the Final Report, Phase III Water Rationing.
Establishing a
partnership with local media outlets is another important aspect of a
successful public outreach campaign. As
part of the material developed for the rationing program, the General Manager,
Water Demand Manager, and the Water Rationing Administrator should make every
effort to secure media interviews through press conferences and releases,
one-on-one contacts, media kits, etc. In
addition, the purchase of air time through the public television broadcasting
stations for the purpose of airing a rationing program slide show (PowerPoint)
would further reach the television audience.
These efforts would be coordinated with CAW’s General Manager, Community
Relations Manager and water conservation staff.
Finally, it is extremely
important to secure the support of other local public agencies. Local land use jurisdictions within the
District, along with the local federal installations/offices, must be
encouraged to place a high priority on enforcement of water use
restrictions. Ideally, each public
entity would partner with the District in the enforcement effort, sending a
unified message to the community.
outreach plan components
- Develop the plan components in coordination with
conservation outreach efforts of other local water purveyors.
- Develop and implement a Rationing Program
website, including on-line electronically transmitted forms and an on-line
payment service.
- Public Service Announcements on radio and
television
- An E-Newsletter with weekly or bi-weekly updates
on the rationing program delivered accurately and with timely information
to other parties, including local governments, news media and water users.
- Presentations to all City Councils/Board of
Supervisors, at a minimum. Also
regular updates during Oral Communications at public meetings.
- Presentations to local service organizations,
homeowner’s associations, clubs, MPC, CSUMB, etc.
- Information booths at fairs, festivals and other
publicly-attended events, particularly those appealing to local water
users.
- Targeted media placements
- Movie theater conservation ad
- Billing inserts (required by Regulation XV)
- Local office with staff available to assist the
public.
- Enlist local public agencies to assist with water
waste enforcement.
- Identify and communicate the location of sources
of sub-potable water supplies available to the public that do not impact
the rationed areas to substitute for potable sources of construction
water, dust control, etc.
Public outreach is
estimated to cost approximately $850,000 annually during rationing. This estimate is based on outreach costs
budgeted by CAW for the 2007 summer water conservation campaign. The bulk of the outreach costs are expected
to be covered by CAW’s rationing outreach budget. A small portion ($50,000 annually) will be
budgeted by the District for direct mailing costs.
Enforcement
The following is the
current (i.e. December 2007) water waste enforcement penalties and procedures
(i.e. Rule 171):
- Water users are given an
opportunity to correct the first occurrence of water waste or
non-essential water use, as those terms are defined by Rule No. 11
(Definitions). Water waste or
non-essential water use which continues after the user has had reasonable
notice to cease and desist that type of water use shall be considered a
flagrant occurrence.
- A $50 fee per day is assessed for
each flagrant occurrence of water waste or non-essential water use. The
fee shall accumulate daily until the occurrence is corrected. Note:
It is difficult to pinpoint exactly when correction of a violation
occurs without documentation from a professional repair person or a
District inspection verifying compliance.
- A $150 fee per day is imposed for
each subsequent occurrence (including multiple occurrences) of water waste
or non-essential water use which occurs within 18 months of the first
occurrence. The fee accumulates daily until the occurrence is
corrected. (See Note above.)
- All fees are to be paid within 30
days.
- Within the 30 day period, a water
user may seek waiver or forgiveness of all or part of the water waste fees
on the basis of hardship. The water user must provide the District with a
written explanation as to why the fees should not be collected. Staff is
authorized to determine whether or not fees should be waived in full or in
part, with the final decision resting with the General Manager.
- After 30 days, fees which have not
been paid or waived may result in a lien being placed on the property
served by the water account.
- Repeated occurrences of water
waste or non-essential water use may result in the placement of a flow restrictor
within the water line or water meter.
- Decisions related to enforcement
of water waste or non-essential water use are appealable.
Data management needs
software
District staff has identified
appropriate programming necessary to make adequate data available to enforce
the rationing program envisioned in Regulation XV. Still unresolved is by whom and how a
rationing data system will be designed.
Staff has also requested a data analysis from CAW to determine if the
non-residential water factors are adequate for rationing. Until this information is available,
proceeding with database programming is not recommended.
Prior to embarking on
programming, the Board needs to determine what changes are needed to implement
a fair and enforceable rationing program.
This is a top priority, and programming should commence on a fast-track at
least six months prior to the anticipated implementation date.
The following data
management needs have been identified:
- CAW consumption data (and other water
distribution system data) must be retrievable by District rationing staff;
- Production limits apply to all users within a
system;
- Program calculates rations based on production
limit, riparian irrigation needs, percentage reduction, and historical
percentage by user group (for non-residential customers);
- Access to census data is required;
- Residential rations must be input and adjustable
as a group based on the number of residents;
- All other user groups must have rations
calculated by the system based on the factor used;
- All rations must be adjustable to accommodate
variances;
- “Water Banks” must be developed for each
customer;
- System must generate enforcement letters and
envelopes when prompted (i.e. warning, notice, final notice, posting
notices, etc.);
- Accounts receivable;
- System must be able to link into new Water Demand
Division database as a component.
hardware
During the first 18
months of rationing in 1989, the staff shared one computer for data entry and
programming, and three “dumb” terminals for viewing data. This deficiency was likely due to the initial
assumption that rationing could last only a short time. Following the report of the Rationing Review
Committee, in March 1990, computer terminals and staff were added and the
system was considerably upgraded.
This Implementation Plan
assumes that rationing will continue for at least five years, and that each
office employee will be using a computer for most of their work. A comparison of costs for leasing and
purchasing will occur prior to action to obtain computer hardware. It is
anticipated that purchasing equipment will be comparable in cost to
leasing. The preliminary estimate for
computer equipment is $106,024. This
estimate is from the District’s Information Technology Officer based on his
professional knowledge and includes a copier/printer/scanner. Copies of the preliminary estimates for
initial purchase of information technology (IT)-related equipment are available
at the District.
website
The Internet is a
valuable tool for educating the public and for disseminating information. In addition to serving as an interactive
method of education, the Internet provides a valuable mechanism for collection
of fees and survey information, and for communication between rationing office
staff and the public. It is recommended
that a website be designed specifically for the rationing program. The rationing website should have basic
information about the program, conservation information and links, frequently
asked questions, various electronic forms related to the program (i.e. survey
forms, variance requests, appeals, etc.), email addresses for rationing staff,
etc. It should also provide the
convenience of electronic payment of water waste fees by bank transfer or
credit card.
budget
CAW Special Request 6
(SR6) provides for establishment of a memorandum account for expanded
conservation and rationing costs billed by the District. This memorandum account was authorized by the
CPUC in the previous General Rate Case (GRC), and was reauthorized under the
same terms. SR6 allows reimbursement by
CAW for expenses up to $100,000 annually in the 2005 GRC.
Special Request 9 (SR9)
is also a memorandum account specific to MPWMD emergency rationing costs. This memorandum account was also approved in
the previous GRC (D.03-02-020, OP 5) and does not state an annual limit. SR9 allows the District to recoup its costs
for expenses related to rationing.
Start up costs for the
rationing program could initially be accommodated by tapping the District’s
conservation reserve fund, currently at approximately $340,000 (July
2007). Funds expended from the reserve
would be replaced upon reimbursement by CAW.
|
PRELIMINARY RATIONING COST ESTIMATES November 2007 |
||
|
|
One Time Costs |
Ongoing Annual Costs |
|
Personnel |
|
1,322,800.00 |
|
Legal Fees |
|
100,000.00 |
|
Hardware/Software |
106,024.00 |
15,000.00 |
|
Database
Programming |
100,000.00 |
10,000.00 |
|
Rent |
|
90,000.00 |
|
Public Education/Outreach
(including mailing costs) |
|
50,000.00 |
|
Travel and
Transportation |
|
3,500.00 |
|
Training |
9,500.00 |
9,500.00 |
|
Furniture and
equipment |
76,000.00 |
5,000.00 |
|
Insurance |
|
|
|
Legal Notices |
|
30,000.00 |
|
Office Supplies |
10,000.00 |
10,000.00 |
|
Miscellaneous |
|
10,000.00 |
|
Total |
$ 301,524 |
$ 1,655,800 |
exhibits
1. MPWMD Regulation XV
2. Water Distribution Systems in MPWMD
Note: Documents referenced but not included in this document may be found on the District’s website in the staff report on this item presented to the Water Demand Committee on September 11, 2007.
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