EXHIBIT 1-C
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Water Demand Committee May
14, 2003 Action Items 4-B: Discuss Process for Documenting Commercial Water Use Credits Related to On-Site Retrofits |
SUMMARY: Staff is seeking direction on assessing water savings associated with retrofits in commercial buildings. As water is less available for changes in use, commercial businesses are looking to retrofitting to offset expanded uses. In the past two months, the District has received two requests for water credit related to installing instant-access hot water recirculating systems. One, a local hotel, recently equipped four 100-gallon water heaters with recirculation pumps. This same hotel also removed a boiler-supplied radiator heating system and replaced it with an electric system. The other, a physical therapist, has requested credit for installing an instant-access hot water system at a health club located on the same site.
District Rule 25.5, Water Use Credits, requires “District staff (1) shall verify that any reduction is one which is permanent, (2) shall quantify the capacity for water use which remains, (3) shall quantify the reduced water use (the abandoned capacity), (4) shall quantify the increment of reduction which exceeds the District’s target of 15 percent conservation based upon the criteria used for the Water Allocation EIR, and (5) shall provide written confirmation of the Water Use Credit based upon the quantity set forth in element (4) above.”
Staff is requesting direction from the Water Demand Committee on how the water savings discussed in subparagraph (3) should be determined. Current staff may not have the expertise to verify with certainty the water savings calculations submitted by applicants, but current staff is often able to assess the reasonableness of water savings estimates. Staff would also like the Committee’s recommendation on whether staff should make a reasonable assessment of the applicant’s submission and make the determination of a Water Use Credit on that premise, or should an outside consultant be retained to verify water savings estimates resulting from commercial retrofits? As the methods used by an applicant to estimate water savings vary widely (examples of the most recent retrofit analyses are attached), staff would request the Committee’s support that staff be authorized to obtain an outside expert’s opinion when needed, with the cost of such review borne by the applicant. If outsourcing is an option, guidelines need to be developed to establish standards to determine which credit requests should be reviewed.
It is also staff’s recommendation that the District maintain some control of the water savings through conditions on any permit issued. The structure of this condition needs to be determined. A deed restriction allowing access to and use of Cal-Am water consumption information should also be a standard condition of a Water Use Credit. This would require the property owner, as well as any tenant, to have some accountability to the District, and the District would be able to use the consumption information to monitor water savings.
Pages 3 and 4 from May 14, 2003 Water Demand Committee
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