Data Requirements to Meet Changes to California’s Drought Regulations
The proposed Emergency Drought Regulations issued by the California State Water Resources Control Board (SWRCB) are an effort to regulate the waste and discretionary use of water, and provide some enforceable standards for water suppliers.
“A key to improving efficiency is understanding where, when, and why we use water.”1
What is interesting is that the metrics proposed in the regulations are practically unattainable, and certainly unenforceable, with the data systems that are in place in most municipalities. In many cases, the metrics proposed will require a wholesale re-evaluation of the collection, use and dissemination of data.
California Code of Regulations (CCR) 23 CCR § 864 End-User Requirements in Promotion of Water Conservation2 currently requires that water suppliers enact management systems that result in the following (in part):
(a) To prevent the waste and unreasonable use of water and to promote water conservation, each of the following actions is prohibited, except where necessary to address an immediate health and safety need or to comply with a term or condition in a permit issued by a state or federal agency:
(1) The application of potable water to outdoor landscapes in a manner that causes runoff such that water flows onto adjacent property, non-irrigated areas, private and public walkways, roadways, parking lots, or structures;
(5) The application of potable water to outdoor landscapes during and within 48 hours after measurable rainfall;
The new changes recently proposed by the SWRCB add prohibition of irrigation of ornamental turf on public street medians with potable water (23 CCR § 864(a)(7)) and impose new restrictions on commercial, industrial and institutional properties:
(c) Immediately upon this subdivision taking effect, all commercial, industrial and institutional properties not served by a water supplier meeting the requirements of Water Code section 10617 or section 350 shall either:
(1) Limit outdoor irrigation of ornamental landscapes or turf with potable water to no more than two days per week; or
(2) Reduce potable water usage by 25 percent for the months of June 2015 through February 2016 as compared to the amount used for the same months in 2013.
In addition, changes to 23 CCR § 865(b) Mandatory Actions by Water Suppliers require that water suppliers:
(1) Provide prompt notice to a customer whenever the supplier obtains information that indicates that a leak may exist within the end-users exclusive control.
To meet these objectives, water suppliers now need to know not only who their customers are, but their designation (commercial, industrial, residential), their location and their intra-day water use. In short, they now need to understand “where, when and how” their customers are using water.
The Devil is in the Details
The objectives set forth in 23 CCR § 864 are not without significant data and operational impacts to utilities.
First, it requires that water suppliers determine both when and how much water is being used for irrigation, when that usage is excessive, and the number of days in a week that usage occurs. This is simply not possible when most meters are read at most once per month, oftentimes without separate irrigation meters. The only option for these municipalities will be to identify these conditions through patrols: police, bylaw enforcement officers, utility personnel or municipal employees. This is a very expensive, inefficient and haphazard methodology.
Second, water suppliers must identify “commercial, industrial and institutional properties.” This means that the utility must have annotated the account as such in their customer information system (CIS), or must do so subsequent to the adoption of the proposed regulations. Municipalities with antiquated CIS platforms will find this a difficult endeavor.
Third, water suppliers must now be able to provide context for water use against prior consumption and be able to communicate with customers about their progress against that standard. To meet the 25% reduction as detailed in 23 CCR § 864(c)(2), property owners will need near to real-time information in order to modify their behavior and actively reduce water use.
Water suppliers will not simply be able to wait until a customer exceeds their reduction requirements and impose fines, resulting in significant increase in customer complaints and service requests. The impact on customer service will be devastating. To be effective, this type of communication must be proactive and time relevant to be useful.
And finally, water suppliers need to know and inform customers when there is a potential leak on their side of the meter. This too will result in significant additional costs to utilities as they monitor and analyze this data and report it to their customers.
Data System Requirements
Meeting the management requirements inferred by the changes to the regulations means that water suppliers must get better at acquiring and maintaining high quality water use data, analyzing that data for the benefit of their customers, and communicating about data in near real-time. In fact, to meet the new regulations, the data itself must be significantly upgraded – water utilities will need consistent, near real-time, geospatial data. This is where the FATHOM Meter Data Management (MDM) platform and FATHOM U2You customer engagement portal excel.
By geo-locating each meter and validating the data within the CIS, FATHOM MDM offers unique insights and opportunities for water suppliers. By coupling FATHOM MDM with the highly granular, near realtime consumption data provided by Advanced Metering Infrastructure (AMI), FATHOM can tell when a customer is irrigating, or if there is a customer-side leak, or if there is other unusual usage.
With FATHOM, water suppliers can track when and how customers are using water and can use programs that automatically identify non-compliant water use, and communicate these conditions in near real-time with their customers. This offers an economical and efficient means of meeting the requirements of the SWRCB’s draft regulations – and provides the basis for continued and sustained conservation.
With FATHOM, water suppliers can also actively engage with their customers allowing effective messaging to be developed. For example:
Based on current water usage trends, you are projected to exceed your potable water usage, which may subject you to a fine of up to five hundred dollars ($500) for each day in which the violation occurs.
Currently, your estimated reduction in water usage will be 18% of the required 25% set forth in 23 CCR § 864 (EndUser Requirements in Promotion of Water Conservation) for commercial, industrial and institutional properties for the months of June 2015 through February 2016 as compared to the same months in 2013.
We recommend that you take action to reduce consumption, access your account to monitor the success of those
actions, and contact us should you need further assistance.
Finally, through the continuous communication opportunities available from the FATHOM U2You customer presentment portal, customers can be proactive about their water use, making more informed decisions. Combined with geospatial comparisons with similar properties, FATHOM U2You is a dynamic instrument of behavioral change.
FATHOM offers water suppliers, utilities and customers the ability to truly understanding the “where, when and why” of water use, and drives sustainability into the water cycle.
1Gleick, P., “Roadmap for sustainable water resources in southwestern North America”, PNAS, 14 December 2010 2http://www.swrcb.ca.gov/waterrights/water_issues/programs/drought/docs/emergency_regulations/draft_emergency_regs.pdfDownload PDF