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.
Staffing/resources needs
and possible revisions to Regulation XV are two areas that need review by the
Board prior to finalization of the Stage 4 through 7 Implementation Plan. Resolution on these issues appears to
directly impact the program and should be given highest priority.
BOARD ACTIONS REQUIRED PRIOR TO PLAN IMPLEMENTATION
The following
actions should be authorized and put into action at least three months prior to
consideration of implementation of Stages 4 or higher:
·
Access agreements with Water Distribution
System Operators and process for obtaining customer consumption data
·
Public Outreach Plan
·
Computer programming
·
Website design
·
Update water conservation regulation
·
Identify mobile water distribution system
operators and obtain compliance with water distribution system rules
·
Prepare job descriptions and recruiting
announcements for rationing staff
·
Adopt a revised enforcement ordinance
·
Adopt revisions to Regulation XV
The following
actions should be authorized and immediately upon consideration of
implementation of Stages 4 or higher:
·
Recruit and hire rationing office staff
·
Secure space needed
·
Purchase/lease office equipment and furniture
·
Set up data management 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 (six positions) - $67,960 annualized
Water Rationing
Specialists I/II/s budgeted at the II level (two positions) - $72,207
annualized
Water Rationing
Technician (two 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 are approximately $975,000, including benefits. 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 database and functions
- 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 (Exhibit
5).
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 and implement a
Rationing Program website, including on-line electronically transmitted
forms and an on-line payment service.
- 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
- Ads in daily and weekly papers
- Stage information
- Rebate program facts
- Drought message with local
drought pictures (make it real and personal)
- Everyone must help message
- Ways to save and ways to save
more
- Inserts in papers
- Public Service Announcements on
radio and television
- Movie theater conservation ad
- Small conservation messages in
sponsored event programs
- Billing inserts (required by
Regulation XV)
- Local “hot line” for telephone
calls
- Conduct enforcement and
compliance training sessions with local governments.
- 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 $300,000 annually during rationing. This estimate is based on advertising costs
budgeted by CAW for the 2007 summer water conservation campaign.
Enforcement
The following is the
current 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;
- System production limits apply
to all users within a system;
- Program calculates rations based
on input for production limit, 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 (Exhibit 6), additional computer terminals and
staff were added and the system was considerably upgraded.
This Implementation Plan
assumes that rationing will continue for at least three years, and that each
office employee will be using a computer terminal 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 $96,300. This estimate is from the
District’s Information Technology Officer based on his professional knowledge
and includes a copier/printer/scanner. Copies
of the estimates for initial purchase of computer-related equipment are
attached as Exhibit 7.
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. 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 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). Expenditure of funds from the reserve would
be replaced upon reimbursement by CAW.
|
PRELIMINARY RATIONING
COST ESTIMATES September 2007 |
||
|
|
One Time Costs |
Ongoing Annual
Costs |
|
Personnel |
|
975,000.00 |
|
Legal Fees |
|
100,000.00 |
|
Hardware/Software |
96,300.00 |
5,000.00 |
|
Database
Programming |
100,000.00 |
10,000.00 |
|
Rent |
|
99,000.00 |
|
Public
Education/Outreach (including mailing costs) |
|
300,000.00 |
|
Travel and
Transportation |
|
3,500.00 |
|
Training |
7,000.00 |
7,000.00 |
|
Furniture and
equipment |
50,000.00 |
5,000.00 |
|
Insurance |
|
|
|
Legal Notices |
|
30,000.00 |
|
Office Supplies |
10,000.00 |
6,000.00 |
|
Miscellaneous |
|
10,000.00 |
|
Total |
$ 263,300 |
$ 1,550,500 |
exhibits
1. MPWMD Regulation XV
2. Water Distribution Systems in MPWMD
3. Rule 32, Water Resource System Production and Sales Limits
4. Non-Disclosure Agreement between CAW and MPWMD
5. Final Report Phase III Rationing
6. Final Report of the Rationing Review Committee
7. Computer Support estimates
U:\demand\Conservation\Rationing\Revised
Rationing Implementation Plan_14Sep07.doc
4:54:58 PM 9/14/2007
U:\Arlene\word\2007\WaterDemand\StaffNotes\091807\item2_exh2A.doc
U:\staff\word\committees\waterdemand\2007\20070918\02\item2_exh2a.doc