WATER DEMAND COMMITTEE |
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DISCUSSION ITEM |
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3. |
DISCUSS
CONSERVATION OFFSET PROGRAM |
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Meeting Date: |
April 18, 2018 |
Budgeted: |
N/A |
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From: |
David J. Stoldt |
Program/ |
N/A |
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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 Approval: N/A |
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Committee Recommendation: |
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CEQA
Compliance: Action does not constitute
a project as defined by the California Environmental Quality Act Guidelines
section 15378. |
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SUMMARY:
At its November
20, 2017 meeting, the Water Demand Committee directed staff to begin to
determine basic provisions of a water conservation offset program. An offset program would allow a developer of
a proposed project in a jurisdiction where an allocation of water is unavailable
to invest in conservation savings elsewhere and use the credit created to
“offset” the required water for the proposed development. At the meeting, the Committee stated its
preference for a program where actual savings will occur, rather than paying
into a mitigation bank to help pay for programs by the District to occur
sometime in the future.
Several
communities have water conservation offset policies (see Exhibit 3-A, attached.) In fact, the District has envisioned such a
program in its Rule 24. Section E of
Rule 24 covers “Special Circumstances” and subsection 6.k. states what is
expected of a developer if a project fails to stay under its calculated Water
Use Capacity limit: “Water use will be
reviewed annually after occupancy. If actual water use exceeds the preliminary
Water Use Capacity estimate during any annual review, the District will debit
the Jurisdiction’s Allocation for the difference. At the end of the monitoring
period, if the average annual water use exceeds the preliminary Water Use Capacity
estimate, the District will determine whether the Jurisdiction shall transfer
some of its Allocation to the Project, or whether
the Applicant shall pay the cost of District-approved water conservation
projects within the District or on the Project Site to establish Water Use
Credits to offset the increased increment of water needed by the Project.”
(emphasis added) To date, the District
has not formalized a process for how it would approve such projects.
The
Committee should discuss the following:
·
Project
specifications: Should the project be
District designed, developer designed, or either?
·
Offset
or credit ratio: Level of savings
required for the credit generated should be considered. Most programs are 1:1, but Soquel Creek is
1.6:1 and some programs are 2:1. The
District has traditionally looked to 15% retirement for the benefit of the
river and recently sought an additional 10% from the Pacific Grove entitlement
for the benefit of a District Reserve.
·
Permanence: Over what lifespan should offset benefits
accrue? How should proposed projects
that do not achieve that lifespan be evaluated?
·
Additionality: A project must create new water savings or
supply that would not/is not expected to have happened anyway, either through
District conservation programs, building code changes, expected customer
behavior, etc. How would this be
determined?
·
Measurability: The water savings or supply from a project
should be able to be quantified. The most effective way of quantifying water
savings is by metering. However, water savings/supply estimates that rely on
the District’s Table 1 “Residential Fixture Unit Count Values” and Table 2
“Non-Residential Water Use Factors” would be more consistent with current
District practice.
EXHIBIT
3-A Examples of Water
Conservation Offset Policies
U:\staff\Board_Committees\WaterDemand\2018\20180418\03\Item-3.docx