Recommendations of the Water Conservation Task Force Presented to the City of Raleigh City Council April 21, 2009
Executive Summary
This report is in response to a request from the City of Raleigh City Council for the Water Conservation to address four specific water conservation items. In addition, this report includes comments and recommendations regarding several related water conservation issues. Thus, the report is divided into two main sections: “Requested Items to Address” and “Additional Recommendations”.
Requested Issues to Address: Year-round Permanent Conservation Measures – The Water Conservation Advisory Council (WCAC) recommended that the number of irrigation days permitted under these conditions remain at 3 days per week (i.e. alternate day) rather than 2 days per week based on address number. In addition, the WCAC suggested that the City adopt language within this ordinance to prohibit flagrant outdoor water waste as well as encourage everyday water conservation by requiring restaurants to only serve potable water when asked by patrons and hotels to only change linens when requested by guests. The Raleigh City Council accepted these recommendations as proposed on September 9, 2008. Certified Vehicle Wash Program Modifications – As part of the City’s conservation plan, a carwash certification program was created to encourage local professional vehicle washes to conserve water and properly maintain their systems. Subsequently, many of the area vehicle washes were certified, and therefore permitted to operate even during severe water use restrictions. One certification criteria for automatic wash systems required that if the facility did not use a water reclaim system, its basic wash package was to consume less than 55 gallons. It was suggested that this volume limit should be examined and modified if necessary. After careful review of presented industry information, it was determined that the 55 gallon per wash limit was a reasonable amount of water and should not be lowered further. However, during the discussions of this issue, the WCAC also made several additional recommendations regarding vehicle washes as listed below:
Provide additional signage to facilities with functioning reclaim systems to delineate them from other certified vehicle washes. Require all future vehicle wash facilities to include an onsite reclaim system. Require certified facilities to be re-inspected on a 3-5 year basis, but this reinspection can be conducted by a certified plumber.
Because conservation technology can change quickly, it is also recommended the program requirements should be reviewed every 3-5 years to ensure the latest standards are being implemented.
Possible Incentive Programs – Currently, the City of Raleigh does not offer a water conservation incentive program beyond an increased water /sewer bill for high levels of consumption. Examples of typical incentive programs include a toilet rebate program, a showerhead exchange program, turf buy back programs, and rebates for water conserving appliances. In the case of a toilet rebate program, a customer who replaces an older model toilet with a modern, efficient toilet can receive either a monetary rebate or a discount on the new toilet if purchased at a participating supplier. The City of Durham for example has designated $360,000 (i.e. up to 3,000 toilets per year) to implement a toilet rebate program which will pay for a portion of a new toilet’s total cost. Showerhead programs usually involve a customer “trading in” their older model showerhead for a new, efficient model at no cost. The concept behind turf buy back programs is to encourage customers who have water intensive turf landscapes to replace it with more native and drought resistant landscapes. In many cases, the program is limited to a relatively small area which qualifies for a refund (e.g. 1000 square feet) due to the potential high costs of such projects. Similarly, a rebate program can be developed to offer a City sponsored discount to customers who purchase water efficient appliances (e.g. appliances such as washing machines, dishwashers, showerheads, toilets, etc... listed as an EPA certified “Water Sense” product). Again, such programs can be cumbersome to implement for the municipality (e.g. ensuring the beneficiary is in fact a customer) and may require some paper work to be completed by the purchaser. Furthermore, such programs rarely result in a measurable decline in system wide demand. Finally, it should also be mentioned that the City of Raleigh is in the process of creating a tiered rate pricing structure for potable water with the goal of encouraging water conservation through higher pricing for inefficient and/or high use. With this in mind, the WCAC offers the following:
Move forward with previously proposed toilet rebate program in which the Public Utilities Department will refund the customer $100 per toilet if it is a Water Sense certified model. It is recommended that this program have no restrictions as to how many toilets per household can qualify and it should be available to nonresidential customers as well.
The Public Utilities Department should develop an incentive plan which would identify additional incentive opportunities (e.g. pre-rinse nozzles at restaurants, clothes washer discounts, Water Sense certified water fixtures, etc..) This plan would evaluate these options, especially as more products are certified through the Water Sense program, and allow for their integration into the incentive program
As with all programs, the incentive program merits significant and sustained advertising and marketing to ensure customers are aware of the opportunities.
The City Council has previously directed the Public Utilities Department to fund the incentive program at a level of $500,000, and this amount should be maintained in the future, if not increased.
Stage III Recommendations – Under the existing conservation plan, there are only 2 stages of water use restrictions, as outlined below: Water Use
Everyday
Stage 1
Odd-Tue, Thu, Sat Odd-Tue, Sat Even-Wed, Fri, Even-Wed, Sun Sun 12-10 am 12-10 am Not regulated Odd-Tue, Sat Certified Auto Even-Wed, Sun irrigation 12-10 am systems Odd-Tue, Thu, Sat Odd-Tue, Sat Hose end Even-Wed, Fri, Even-Wed, Sun sprinklers Sun 6-10 am & 6-10 6-10 am & 6-10 pm pm Odd-Tue, Sat. Hand Held Hose Not regulated Even-Wed, Sun 6-10 am & 6-10 pm Not regulated Drip Irrigation Not regulated Auto & NonAuto irrigation systems
New Landscape Anytime for 45 days from Est. Permit installation Swimming Pools Not regulated
Vehicle Washing Not regulated
Pressure Washing
Not regulated
No longer issued
Stage 2 Prohibited
Prohibited
Prohibited
Prohibited
Prohibited Not issued after effective date
Existing pools may Top off for be topped off sanitary purposes only Commercial OK; City Certified Residents Commercial car prohibited washes only Commercial OK; Prohibited except Residents Sat/Sun for sanitary & health exceptions
However, it was deemed necessary that the City examine further water use restrictions beyond Stage II to address catastrophic drought conditions. Based on the City’s experience under Stage II during the 2007/2008 drought, it was clear that the easily enforced outdoor water restrictions were already in place and it consequently only resulted in a ~3% further reduction compared to Stage 1 Amended. It addition, it should be noted that the largest two categories of water users are the residential and commercial components (i.e. Residential = 27.63 MGD, Commercial = 10.89 MGD, Industrial = 1.3 MGD, and Institutional = 4.68 MGD). With this in mind, the WCAC indicated that in order to realize a meaningful water use reduction, the residential indoor water-use component must be addressed. Because of the inherit inequities of closing only certain businesses (e.g. vehicle washes or restaurants), this approach was not deemed to be a realistic or an effective means to further curb water consumption. Although, it may be possible to require a percent reduction for all potable water customers (regardless of use category), but this concept presents significant technical challenges in how the reductions would be calculated and enforced. Plus, there are several large industrial customers for instance that have already implemented water efficient upgrades and consequently cannot make further reductions without reducing and/or halting production altogether. However, a requested percent reduction of the residential category may be more feasible. For example, when Stage I is implemented, the City could request that customers reduce their domestic consumption to 55 gallons per day per person, Stage II would request a reduction to 35 gallons per day per person, and Stage III would request a reduction to 25 gallons per day per person. While such a strategy does not require a reduction, it does raise public awareness and provides clear targets for customers, which most likely would yield a measureable decrease in overall demand. It is also agreed that a long-term goal should be a move toward water budgeting as more sophisticated technology such as AMR and billing software are fully implemented and conservation staff are increased. The WCAC also recognizes the work that the Triangle J Council of Government (TJCOG) has conducted through the Regional Conservation Work Group (RCWG). This group consists of the area municipal water providers (i.e. City of Raleigh, Town of Cary, City of Durham, Town of Apex, and Orange Water & Sewer Authority) and was tasked with aligning the outdoor irrigation restrictions of all parties. This agreement would provide residents within Wake, Orange, and Durham Counties a consistent message regarding outdoor irrigation restrictions. To this end, the WCAC fully endorses the proposed system of irrigation restrictions as described below:
Furthermore, because very little reduction in demand can be realized be realized by limiting and/or eliminating such activities as power washing, pool operations, and residential vehicle washing, it is recommended that these activities not be regulated until Stage III. This would allow Public Utilities enforcement staff to spend more time focusing on irrigation related issues, reduce public confusion about conservation measures in Stage I & II, and further align City of Raleigh’s conservation measures with other surrounding systems.
Additional Recommendations: During the course of discussing the original four issues requested by City Council, the Water Conservation Advisory Council (WCAC) also developed recommendations for additional aspects of water conservation as listed below:
Risk Based Conservation Triggers: Currently, the water conservation plan has prescribed guidelines as to when the City should consider implementing different stages of water use restrictions. These guidelines are based on the percent remaining in the water supply pool at the Falls Lake Reservoir: a) Over 70% available water supply capacity – every day water conservation rules and voluntary water conservation best management practices are in effect. b) 70% or lower available - stage 1 mandatory water conservation rules may be necessary. c) 50% or lower available – stage 2 mandatory water conservation rules may be necessary.
While this type of system is in effect a “risk based” approach, it is not considered to be a precise way to measure water supply as it is based on a 30 day rolling average demand (which can vary wildly in warmer months) and the time of year and other historical data is not taken into consideration. Thus it is strongly recommended that a risk based water supply assessment system, which uses the recently developed Falls Lake watershed model, should be adopted. This type of system would use historical local weather data and records to predict the likelihood of severe drought conditions. Thus, the City could designate how much “risk” is acceptable and implement water conservation measures when a certain risk level was reached. Such a system would eliminate much of the ambiguity of the current implementation system and allow for easier comprehension by customers and media. Examples of municipalities which have adopted such risk based systems are the City of Ashville and the Town of Rocky Mount, and consequently both were able to properly manage their respective water supplies in the 2007/2008 drought.
Create a Public Information Officer for the Public Utilities Department: Because of increased media attention during the 2007/2008 drought, it became necessary to dedicate significant amounts of staff time to interacting with the media and providing accurate information to them. Not only was it necessary that staff possess adequate public relations skills, but it was also crucial that staff have a clear and full understanding of the technical issues pertaining to water supply. Furthermore, because of the ever increasing number of critical utility projects underway and scheduled for construction, it is clear that a department Public Information Officer (PIO) could provide a much needed connection with the public and local media. Projects such as the construction of a new water treatment plant, development of a new drinking water reservoir, expansion of the Reclaimed water system, odor control upgrades for pump stations, and nutrient removal through an advanced Bio-Solids program are all complex and important issues that require specific technical expertise to explain properly. Similar to the City’s Police Department PIO, this proposed position would be a direct liaison between the Utilities Department and the public.
Ongoing Public Education Campaign: The serious conditions of the 2007/2008 drought clearly illustrated the water supply limitations of the Triangle area and the need for further public education on the issue of water conservation. It has been stated many times that the City of Raleigh strives to be one of, if not the, “greenest” City in the Southeast, and as part of this goal, the City of Raleigh should establish itself as a leader in water conservation. However, in order to effectively educate the public about this critical issue, more financial resources should be dedicated to an ongoing multi-media education campaign employing television commercials, radio ads, outreach programs, news letters, and free water saving devices. In essence, the goal of such a program should be to consistently present the water conservation message throughout the year, regardless of current climatic conditions. This endeavor would require a significant amount of funding, and therefore partnerships with
surrounding systems should be developed, as well as partnerships with members within the business community to help provide financial aid. If such a program was effective in convincing a large portion of the customer base to truly value drinking water, it is expected that average per capita consumption would decrease.
Issue Drought Advisories prior to moving into higher levels of water use restrictions: Using the same concept the Town of Cary has adopted, it is advisable to publically release a “Drought Advisory” to the customer base warning of possible impending drought conditions and describing what the next level of water use restrictions could be. Such action can encourage customers to use less water on a per capita basis and thereby reduce the overall demand for drinking water. In addition, this would give customers ample time to fully understand any additional water use restrictions which may be implemented.
Require Certified AWWA Water Efficiency Audits by all large water users: Under the existing water conservation plan, a large water user is defined as a customer that consumes over 100,000 gallons per day. The conservation plan also requires that said large water users must submit a plan to Public Utilities Department outlining their conservation practices. While the current group of defined large water users have submitted their respective water conservation plans, there are no specific technical requirements under the water conservation ordinance. Thus, it is clear that this group of large water users should conduct an American Water Works Association (AWWA) water efficiency audit to bring a level of standardization to the conservation plans. It should be noted that these audits can be performed by staff with state’s Pollution Prevention Unit located in downtown Raleigh, staff at the Triangle J Council of Government, or by most industrial engineering firms. It is also suggested that these audits are conducted once every 5 years to monitor progress and implementation of new, efficient technologies.
Modify Current Golf Course Irrigation Restrictions : Under the current water conservation plan, golf courses are regulated under the same irrigation rules at residential landscapes. Thus, under the Stage II water use restrictions, these facilities were not permitted to irrigate any part of their property, thereby exposing the greens to permanent damage. However, due to their employment capacity, careful monitoring of water use (i.e. too much water can be detrimental to turf grasses), and financial investment in the greens, it has been suggested that a stepped percent reduction system be created for golf courses. One possible example is as follows:
Stage I Restrictions A.) Golf Courses will reduce water usage by 25% based on a 5 year non restrictive average. B.) Educate customers and employees on the need to conserve water and how to prepare for drought conditions. C.) Inspect water delivery system components and ensure that existing equipment is operating as efficiently as possible. Stage II Restrictions A.) Golf Courses will reduce water usage by 50% based on a 5 year non restrictive average. B.) Same as above C.) Same as above Stage III Restrictions A.) Golf Courses will reduce water usage be 75% based on 5 year non restrictive average. B.) Same as above C.) Same as above
Modify Current Building Code for Water Fixtures: Under the existing ordinance, the City code does not require water fixtures be any more efficient that the current state plumbing code. This section of the state plumbing code has not been revised since 1994, and there have been numerous improvements in water efficient fixtures since that time. For instance, the current code calls for toilets to use 1.6 gallons per flush, where there are several models available now that only consume 1.28 gallons per flush (or less). Similar improvements have been made in regards to showerheads (current = 2.5 gallons per minute, new high efficiency models = 1.5 gallons) and faucet aerators (current = 1.5 gallons per minute or high, new high efficiency models = 0.5 gallons). Therefore, if the City of Raleigh updated its own building code requirements for water fixtures, this would result in significantly more efficient new homes and buildings.
Partnership With Local Business Entities: Because the City of Raleigh is fortunate to be the home of a variety of renowned and successful businesses, the WCAC suggested that perhaps a corporate partnership could be formed with the City of Raleigh. This corporate partnership would work with the City of Raleigh to help deliver the water conservation message through event sponsorship, help with advertising campaigns, and working through their respective community channels to encourage water conservation. Partnership members would be publically recognized by the City of Raleigh for their efforts.
Create Standing Water Conservation Advisory Council: As conditions and technology changes, it may become necessary to assemble a permanent WCAC could convene annually or perhaps bi-annually to evaluate the effectiveness of the water conservation programs and/or any new advancements in water efficiency technology. This WCAC would be appointed by the City Council and facilitated by the Public Utilities Department.
Discontinue the Regulation of Minor Water Usages in Stages 1 and 2: As was recognized in the 2007/2008 drought, elimination of such water usages as power washing, residential car washing, and pool filling made no measureable reduction in overall water consumption. Department regulation of these activities also created an additional work load on enforcement staff, and caused a great deal of confusion with the general public and even City employees. Therefore, it is suggested that these activities on be regulated under a proposed Stage III of water conservation measures and only focus on irrigation restrictions under Stage 1 and 2.