WATER DEMAND COMMITTEE |
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ITEM: |
DISCUSSION
ITEMS |
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5. |
DISCUSS DEVELOPMENT OF POLICY ON USE OF
ATMOSPHERIC GENERATORS AS A WATER SOURCE |
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Meeting
Date: |
June 12, 2014 |
Budgeted: |
N/A |
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From: |
David J.
Stoldt, |
Program/ |
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General
Manager |
Line Item No.: |
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Prepared
By: |
David J.
Stoldt |
Cost
Estimate: |
N/A |
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General Counsel Review: N/A |
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Committee Recommendation: N/A |
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CEQA Compliance: N/A |
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SUMMARY: At a Board
meeting earlier this year, local architect Ron Brown brought the concept of
atmospheric water generators (“AWGs”) as a potential
supply option for the Water Management District’s service area. Since that time, District staff have attended
a demonstration by the EcoloBlue USA company and researched their corporate information. An EcoloBlue model
30s water cooler is presently being demonstrated in the District’s lobby.
RECOMMENDATION: With limited water allocations available from the jurisdictions and at least 4 years before the lifting of the Cease and Desist Order (“CDO”), the District is likely to be asked to approve Water Permits based on the use of AWG devices. Therefore, the Committee should discuss potential policy objectives related to (a) County Environmental Health Department concerns, (b) establishment of a Water Use Credit where applicable, (c) calculation of District’s Capacity Fee, (d) relationship to the water allocation process, and (e) other issues such as energy use and/or noise.
DISCUSSION: There are
several companies that provide similar products, all of which operate in a manner very similar to
that of a dehumidifier: air is passed over a cooled coil, causing water to
condense. The rate of water production depends on the ambient temperature,
humidity, the volume of air passing over the coil, and the machine's capacity
to cool the coil. Attached as Exhibit 5-A
is an EcoloBlue summary document submitted to the
County of Santa Clara which provides an overview of the uses for the
product. Also included in Exhibit 5-B
is an overview of the 30s model which is in the District lobby, but paired in
the brochure with a solar array for power.
Exhibit 5-C provides specifications on several of
the EcoloBlue models of increasing capacity.
(a) County Environmental
Health Department concerns: In discussions with County
personnel, District staff have learned that the County will not
permit the use of AWGs as the primary water source for domestic residential
use, rather will require a cross-connection with some other reliable potable
source. This is due to the undocumented
reliability of production in the regional setting. The County will consider permitting AWGs as a
supplemental or non-residential source, as well as possible use for graywater-style purposes.
The permit process would be done in conjunction with a building permit. Properties would likely be deed restricted
for the non-residential or supplemental-only dedication of use.
The County will also look to ANSI/NSF certification for any potable
installation or use. Any company that
manufactures, sells, or distributes water treatment or distribution products in
North America is required to comply with NSF/ANSI Standard 61: Drinking Water
System Components – Health Effects by most governmental agencies that regulate
drinking water supplies. Developed by a team of scientists, industry experts
and key industry stakeholders, NSF/ANSI 61 sets health effects criteria for
many water system components including:
There may be other ANSI/NSF requirements that must be met. EcoloBlue does not
presently have ANSI/NSF certification, but will be pursuing all necessary
certifications going forward.
(b) Establishment of a Water
Use Credit where applicable: Due to cost of operation, it is
unlikely that an end user would seek to use AWGs as a means to disconnect from
Cal-Am and to establish a Water Use Credit.
Typically, the District would require the permanent abandonment of
Cal-Am in order to establish a Water Use Credit. However, given the likely stance of the
County regarding cross-connection and supplemental use, the District may need
to consider how Water Use Credit might be calculated even with a redundant
Cal-Am connection. There appear to be
other similar circumstances warranting reconsideration of the Water Use Credit
determination such as using well water or cisterns to offset the use of potable
water for flushing toilets on a part-time basis.
(c) Calculation of
District’s Capacity Fee: The District’s Capacity Fee for a new use is
calculated pursuant to Rule 24 C through F.
The District must decide whether to assess a Capacity Fee similar to a
new well connection, a Cal-Am connection, or something else.
(d) Relationship to the water allocation process: In some respects, AWGs represent new water supply. The District will need to determine how to “count” the water and what it means relative to existing and future water allocations. To the extent a AWG device offsets existing Cal-Am service in a jurisdiction, can a Credit be established and returned to the jurisdiction’s allocation? Do AWGs represent local projects under the Section 19.2 of the CDO which states, “Any Monterey Peninsula Community that Wishes to Develop Water from a New Source for Growth Must First Apply Water from the New Source to Reduce its Share of the Water Being Illegally Diverted by Cal-Am; Only after its Share of Illegal Diversions from the River is Ended may Water from the New Source be Used for Growth”? If a land use regulatory body has approved multiple projects utilizing AWGs, should the District care about the cumulative effect on water supply? (i.e. should the District regulate how much water may be provided through AWGs?)
(e) Other issues such as cost,
energy use and/or noise: Additional issues where the District may
have no regulatory purview, but are interesting nevertheless, include cost,
energy, and noise.
The capital cost of AWG versus other sources is high. For example, the proposed 9,752 AFY Cal-Am
desal plant at $253.4 million is approximately $26,000 per AFY. To the contrary, a 404 AFY AWG plant comes in
at $73,000 per AFY if connected to traditional power and $105,000 per AFY if
fully solar powered. Smaller scale AWG
such as would provide 0.163 AFY – sufficient for a single family home – has a
capital cost on the order of $145,000 per AFY.
Annual cost of power is also of concern.
As an example, a 6,000 liter per day AWG system consumes energy at a
rate of 0.514 kWh per liter. This
equates to an annual energy expense of $82,412 per AF. The most energy efficient small unit equates
to approximately $65,200 per AF.
When powered by traditional carbon-based electricity AWG has one of the
worst carbon footprints of any water source (significantly exceeding reverse
osmosis seawater desalination) and it demands more than four times as much
water up the supply chain as it delivers to the user.1 The Monterey Bay Unified Air Pollution
Control District has indicated it would not regulate individual consumer-based
units, but any large scale centralized project especially if sponsored by a
municipality or public agency would draw their attention.
Finally, noise during operation can be of concern. If the District moves forward with a
framework for approval of AWG units, it may consider sharing its knowledge with
the jurisdictional building departments to ensure they draft comprehensive
specifications for approval in design and construction.
EXHIBITS
5-A EcoloBlue Summary
to the County of Santa Clara
5-B Overview
of the 30s Model with Solar Power.
5-C Specifications
on EcoloBlue Models
Note 1: Environmental Assessment of Air to Water
Machines. International Journal of Life Cycle Assessment, 18:1149-1157.
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