WATER DEMAND COMMITTEE

ITEM:		ACTION ITEM
1.	Consider Recommendation to Board on Process for Reviewing Proposals to Utilize Conservation Retrofits IN NON-RESIDENTIAL USES
Meeting Date:			October 12, 2004	Budgeted:	No
From:			David A. Berger,	Program/	N/A
			General Manager	Line Item No.:

SUMMARY: Commercial (i.e., non-residential) water demand is calculated using factors by type of use that are derived from regional averages and that have been grouped into three categories. District Rule 24, Table 2, Commercial Water Use Factors, (Exhibit 1-A), shows the three categories and the uses associated with each category. In the past several years, as water has become less available, the District has received several creative proposals for retrofitting (i.e., replacing existing appliances or water fixtures with ones that use less water) to create water savings to offset new or expanded uses. Retrofitting of specific water fixtures was not contemplated when the commercial factors were adopted. The calculation of water savings associated with retrofitting individual fixtures is extremely difficult to quantify, as the specific uses of water in each type of use (facility) were not considered when the factors were compiled.

In 2000, the District received several water permit applications that included ultra-low consumption technology as a component of the project (e.g. ozone-treated recycled laundry water, half-gallon toilets and waterless urinals). At that time, staff reviewed and accepted, rejected or modified the calculations of the applicants; taking into consideration any information available regarding specific water use by fixture in the proposed uses and information provided by the manufacturers of the low-consumption products. Ultimately, those applications met the criteria of “substantial uncertainty” regarding the water use projections and were brought to the Board for consideration of “special circumstances” under District Rule 24-G (attached as Exhibit 1-B. Staff later decided that its information about water use in non-residential uses (City of Santa Barbara Water Demand Factor and Conservation Study, 1989) could not be relied on to approximate the water savings associated with interior or exterior retrofits due to the age of the data. Furthermore, the District conducted a survey on the satisfaction and use of the half-gallon toilets and concluded that water savings may not be as great as anticipated. Toward the end of 2002, the District’s Water Demand Committee began reviewing and providing direction on special circumstances applications and on handling future requests for commercial water use credits.

On May 14, 2003, the former Water Demand Committee provided direction to staff on processing requests for Water Use Credit in non-residential settings. The committee agreed that if staff does not have the expertise or previous experience to calculate a credit, or when there is some circumstance that makes the situation unusual, a consultant should be retained to calculate the water use credit. Proposals that include new technology or a new approach that staff is unfamiliar with should be presented to the Water Demand Committee and the Board for further direction. Copies of the staff report and minutes from the May 13, 2003, meeting are attached as Exhibit 1-C.

In March 2004, staff met with representatives of PMCL@CDM (Planning and Management Consultants, Ltd., a subsidiary of Camp Dresser & McKee Inc.) to discuss retaining the firm to review applications for commercial water use credits. PMCL@CDM prepared the extensive and professional report on water savings achieved at the Presidio of Monterey when the Presidio retrofitted the facility’s urinals to waterless urinals and installed a SOMAT disposal system. The Board approved a water use credit for the Presidio of Monterey in March 2004. Board members were given a copy of the PMCL report prior to the March board meeting.

In recent discussions with PMCL@CDM, it became apparent that the District needs to prepare a scope of work before it is possible to either retain the consultant or to determine the potential costs associated with their review of water use credit requests. At this time, staff is aware of several commercial projects that have been planned and that rely on water use credits from new technology to offset their expansions in use. Staff has not had the time or resources to prepare a scope of work for the consultants. As no funds are budgeted in the fiscal year 2004-2005 budget for assistance with this project, staff has been unable to retain a consultant or to respond to requests to review water savings for installing ultra-low consumption fixtures. Direction is needed on receiving and processing requests for credit in non-residential uses, particularly when the credit is proposed to offset a new or expanding use.

RECOMMENDATION: Staff recommends that the Water Demand Committee propose to the Board that requests to utilize ultra-low consumption technology at the onset of a project (to offset an expansion in use) be considered after a consultant can be retained by the District (at the applicant’s expense) to review the proposed water savings. This review should also consider the water use associated with the specific type of use (not using a “grouped” factor). Water Use Credits should be available for ultra-low consumption technology when the applicant has applied in advance to the District and water savings have been clearly documented over time using metered water use that can be verified by the District. An example of this type of application is the water savings achieved at the Presidio of Monterey.

A scope of work for reviewing commercial water use credit requests can be prepared and released during the first two months of 2005. Funding for the District to retain a consultant to review commercial water use credit requests will be included in the 2005-2006 budget. Staff believes that there are instances when the District would benefit from the expertise of an experienced water use consultant to review unusual commercial projects that do not fall into one of the existing commercial categories of use (e.g., the District recently completed a review of its assisted living facility factor). The remaining scope of work would involve review of specific applications that would be paid for by the applicant at a predetermined hourly fee.

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